Environmental

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Ch.19AddendumPages.pdf

ADDENDUM A

MOC EXAMPLE 1

ALPHA CORPORATION

Pre-Job Plannlng and Safety Analysls Outllne I. Review the work to be done. Consider both productivity and safety:

a. Break the job down into manageable tasks. b. How is each task to be done? c. In what order are tasks to be done? d. What equipment or materials are needed? e. Are any particular skills required?

2. Clearly assign responsibilities. 3. Who is to perform the pre-use of equipment tests? 4· Will the work require: a hot work permit; a confined entry permit, lockout/tagout

( of what equipment or machinery), other? 5· Will it be necessary to barricade for clear work zones? 6· Will aerial lifts be required? 7· What personal protective equipment will be needed? 8· Will fall protection be required?

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9. What are the hazards in each task? Consider - Access Work at heights Work at depths Fall Hazards Worker position Worker posture Twisting, bending Weight of objects Elevated loads Welding Fire Explosion Electricity Chemicals Dusts Noise Weather Sharp objects Steam Vibration Stored energy Dropping tools Pressure Hot objects Forklift trucks Conveyors Moving equipment Machine guardin

10. Of the hazards identified, do any present severe risk of injury? g 11 . Develop hazard control measures, applying the Safety Decision Hierarchy,

• Eliminate hazards and risks through system and work methods design and redesign

• Reduce risks by substituting less hazardous methods or materials • Incorporate safety devices (fixed guards, interlocks) • Provide warning systems • Apply administrative controls (work methods, training, etc.) • Provide personal protective equipment

12. Is any special contingency planning necessary (people, procedures)? 13. What communication devices will be needed (two-way, hand signals)? 14. Review and test the communication system to notify the emergency team (phone

number, responsibilities). 15. What are the workers to do if the work doesn't go as planned? 16. Considering all of the foregoing, are the risks acceptable? If not, what action

should be taken?

Upon Job Completion

17. Account for all personnel 18. Replace guards 19. Remove safety locks 20. Restore energy as appropriate 21. Remove barriers/devices to secure area 22. Account for tools 23. Tum in permits 24. Clean the area 25. Communicate to others affected that the job is done 26. Document all modifications to prints and appropriate files

ADDENDUM B

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MOC EXAMPLE 3

GAMMA CORPORATION

Pre-Task Analysls

Completed fo~ must be submitted and work must be authorized before activity is commenced Submitted by ________ Date ____ Location _____ _ Description of work ____________________ _

Commencement date ______ Expected completion date ____ _

Permits, special skills and licenses: Work must not be.•commenced if required Permits have not been received or if arrangements have not been made for the special skills and licenses required.

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Permits Required Received Confined space __ Yes No __ Yes -No Electrical Yes No __ Yes -No Combustion equipment Yes No __ Yes __ No Excavation Yes No __ Yes __ No Hot work Yes No __ Yes __ No Lifting-rigging Yes No __ Yes __ No Fire systems Yes No __ Yes __ No

Obtained Will special skills be required Yes No __ Yes __ No Will special licenses be needed Yes No __ Yes __ No

Check off each of the following that apply. Each checke<J subject is to be addressed in the pre-task planning. · · -

_ Lockout/fagout _ Pinch points _ Inadequate access Hot/cold/burns _ Chemical exposure/spill _ Electrical shock

_ Sharp objects Excavations _ Equipment loading/unloading Asbestos _ Falling objects _ Particles in eye Elevated work _ Fall from height _ Manual lifting

_ Lighting _ Lifting or rigging _ Mobile equipment Isolated area Radiation _ Fire/explosion

_ Ladder usage ·_Confined space Heat stress _ High noise levels _ Scaffolding Inhalation hazard

Other Other Other Other Other

Specify personal protective equipment needed ___________ _

Specify special equipment needed if any------~------ "

H unexpected and unacceptable risks are encountered, it must be understood that work is to be stopped until the situation is resolved. This provision must be made clear in pre-job discussions and in employee briefings.

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1oyee briefings. Supervisors are to assure that all employees involved in the work ·efed on the order of and the procedures to be followed and of risks considered

are n ...... J· ob discussions. intheP"

Naroe Signature Date Name Signature Date -- L---" ,__. Additiorutl space is provided for the briermgs of personnel added after the work is co111111enced.

- Signature Date Name Signature Date Name - Notifications: Names of persons to be notified before the work is commenced and after it is completed.

Pre-work commencement Names

Upon completion Names

Department

Department

For emergencies encountered, list names and phone numbers of the people who should be notified.

Names Department Phone Number

Approval signatures

Safety and environmental personnel, who are to assure that foreseeable hazards have been identified and risk control methods are appropriate

Date ____ _

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Manager with authority to approve the project

Upon completion

All personnel, tools and equipment accounted for __ Yes __ No Operation successfully restored __ Yes __ No

Signature: Project initiator __________ Date ____ _

ADDENDUM C

MOC EXAMPLE 4

A COMPOSITE MANAGEMENT .SYSTEM GUIDE FOR MOC SYSTEMS

Using several resources on management of change and reflecting on my experience, the following general statement on a management of change policy and procedures is offered as a guide for reflection by those who initiate MOC systems. Note that it encompasses both occupational safety and environmental considerations. It is a brief

'•! management guide only and is presented as such. It does not contain any forms. This composite guide is worthy of thought. It will serve well as a resource in initiatives to adopt the m1µ1agement of change provisio~s in ZlO.

Management of Change Polley and Procedures: Occupatlonal Safety and Health and Envlronmental Considerations

1,0verview This policy defines the requirements for a management of change process with respect to occupational safety and health and environmental consideratipns.

2,Purpose This Ii . ., · env· po cy establishes a process for evaluating occupational safety and health and

Ironmental exposures when ope_rational changes are made so as to control the

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internal risks during the change process and to avoid bringing new hazards and risks into the workplace.

3. Scope This policy applies to all operations at this location: there are no exceptions.

4. Responsibility a. The Management Executive Committee, with counsel from the senior safety

professional, is responsible for establishing processes to determine when these management of change procedures shall apply, how they are to be implemented and by whom, and to follow the processes through to an effective conclusion.

b. Facility management is responsible for ensuring that these processes and proce- dures to address the safety, health, and environmental implications of operational changes are implemented within their areas of responsibility.

c. Employees at all levels-division managers, supervisors, line operators, and ancillary personnel-after receiving training on this policy and process, are responsible within their domains of influence for initiating communications on operational changes that may have an impact on safety, health, and environmental considerations and for the implementation of this policy and process.

d. All safety professionals have responsibility to i,dentify operational changes that require study as to hazard and risk potential and to bring their observations to management's attention through their organizational structures.

5. Application a. This policy applies to all operational changes that may potentially affect on the

safety and health of employees and on our environmental controls. b. This policy will be implemented as an adj'unct to all issued Safety, Health,

and Environmental. policies and procedures, but particularly to our Design and Procurement of Equipment arid Facilities Procedure.

c. The senior safety professional, and other safety professionals with particular skills shall participate routinely in management staff meetings when operational changes are discussed.

d. A safety professional will sign off on the change plans considering the provisions of our Design and Procurement of Equipment and Facilities Procedure and on the New Product Development process.

e. Examples of operational changes to ..yhich this policy and process may apply include: · • Unusual , nonroutine, nonproduction work, work where high-energy exposures

are contemplated, and maintenance projects for which the scope of the work requires a determination that pre-job planning and safety analysis would be beneficial

• Revisions in operating methods and procedures • Revised production goals • Plans to lower operating costs • Revisions in staffing levels, upward or downward

A COMPOSITE MANAGEMENT SYSTEM GUIDE FOR MOC SYSTEMS 387

, organizational res~cturing , Revisions in the envrronmental management system , New product development , Adoption of new information technology that has an impact on operations , Changes in safety, health, or environmental regulations , Acquisitions, mergers, expansions, relocations, or divestitures

6_ Management of Change_ ~te~ . . . When an operational change 1s identified that requrres study as respects its rrnpact on occupational safety, health, o~ environmental controls, a person at an _appropriate management level shall be appointed the maqagement of change champion to chap- eron the review process to a conclusion.

a. That person, having obtained counsel from safety professionals, will determine how extensive the review procedure will be and decide on whether: , Completion ofaManagement of Change Request Form is necessary [Figure 19.1]

within which the accountability and sign-off levels are set forth , Multidisciplinary group discussions are to be held to encompass the content

of the Pre-Job Planning and Safety Analysis Outline [Addendum BJ • The hazards and risks that may result as the operational change moves forward

are of greater significance and require appointment of an ad hoc Management of Change Committee to oversee the project. Safety professionals having the necessary skills are to be members of such committees.

• Our Capital Expenditure Request Procedure is to be initiated

7. The Management of Change Champion shall: a. Assure that input on the operational change has been obtained from all who

might be affected. b. Arrange for resources, staffing, and scheduling to accomplish the change. c. Schedule the necessary risk assessment. d. Obtain comments from line operating personnel on their views on how the

hazards and risks can be ameliorated, and their concerns. e. Get safety personnel to sign off. f. Follow the review process to a logical conclusion. g. Arrange a final review of the changes made to assure that hazards and risks

have been addressed properly. h. :ermine that residual risks, after risk reduction and control measures have . S n taken, are acceptable. 1. , ee tbat documentation is appropriate.

The Management of Change Champion is to give emphasis to documenting ~I changes made that should be recorded in prints and appropriate files so

h at persons who make further changes at a later date will know precisely

w at was done. • : ~~ng decisions_ on what doc~mentation is to be made, this principle is to , l\Y· Be supercautious and consider later needs.

s assessments are to be retained in accord with our document retention policy.

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j. Have Standard Operating Procedures modified as necessary. k. Determine whether additional training is necessary.

8. Training a. Personnel responsible for safety, health, and environmental training at the

management, supervisory, line worker, and ancillary personnel levels shall incorporate this policy and process into the training curricula.

b. Employees shall receive training on the revised Standard Operating Procedures before changes are finalized.

c. In the training process, employees will be p_roperly informed with respect to their assuming responsibility for the aspects of safety, health, and environmental matters over which they have control.

ADDENDUM D

MOC EXAMPLE 10

This is S&IH Bulletin 423221, effective date June '1, 2008.

LAMBDA CORPORATION

Management of Change Polley for Safety and Envlronmental Risks

1. Overview ' This document outlines the requirements for Management of Change with respect to safety and environmental risks.

2.Purpose 2.1 To establish a process requiring early reviews of vari~us business changes to

diminish the probability of or prevent the occurrence of adverse effects that may impact the safety of associates, the public, equipment or facilities, and

• I I associated environmental aspects.

3.Scope 3. I 3.2

This policy applies to all domestic and international operations . To address potential impact on safety or environmental issues when various changes outlined in this process are proposed, and the related management of those changes.

S ced Safety Ma eecond Edition F nagement: Focu sing 011 Z/0 and Serious Injury Prevention. 2014 John W"i red A. Manuele.

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3.3 For reference only, various fonns may be found in Appendix Section_ 7.~. Othe~ may be hyperlinked to other respective documents or Web pages as indicated in this document.

4. Definitions . . 4.1 Change Control- Mechanism or tool used by the organization to control

identi fi ed changes in the organization. . . 4.2 Design for Environment (DfE}-An environmental review process for all

products, packaging, and processes in the research and development phase- includes all new and changed products.

4.3 Due Di!igenre-A pre-purchase/pre-lease or exit audit for acquisitions, divesti. tures, leases or joint ventures of all business related aspects and real estate propeny to ensure that potential liabilities are identified.

4.4 Environmental Impact Assessment (EIA}-a reference tool for Environmental Professionals conducting Environmental Impact Assessments of facility-related projects, new or modified equipment, new materials and new or modified processes being implemented at the location.

4.5 Ergonomic Job Analysis/Analyzer (EJA}-An analysis tool used to evaluate jobs and tasks to rate them by level of ergonomic risk.

4.6 MAP (Management Action Plan}-A tracking tool that incorporates items identified during an annual operating location self-assessment, or of issues identified during any of the risk assessments as listed in this policy.

4.7 Production Standards-The value of the production work that has been determined through methodical evaluation to be reasonably expected during an allotted time period.

4.8 Project Leader-The term project leader is used in the generic sense. If a person is assigned the responsibility to manage a project, that person in essence is a project leader.

4.9 S&IH (Safety & Industrial Hygiene)-A Lambda organization within the technical Resource Group (TRG).

5. Responsibilities The responsibilities of the personnel required to administer the management of change process are listed as follows :

5.1 Environmental Professional Resources

EPR shall be responsible for conducting environmental assessments as needed. This includes, but may not be limited to, an Environmental Impact Assessment.

5.2 S&IH Professional Resources

Maintains this policy and ensures its existence at the affected locations. S&IH shall_ be responsible for providing the technical resources to comply with the requirements of this policy. S&IH Professionals shall work with Environmental Prof~ssionals at the respective operating location

10 ensure compliance to applicable standards.

5.2.1 A review of this policy shall be conducted during the annual self- assessment or whenever this policy fails to serve the purpose of its intent.

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5_2.2 Deficiencies noted in this policy shall be incorporated into the operating location MAP to ensure that corrective actions are tracked and completed.

Global Franchise Management Board Members ;.3 Shall ensure compliance with this standard for their respective organizations

described in the scope of this document. ;.4 Line Management

Shall be responsible for ensuring that the requirements and procedures contained in this policy are implemented and adhered to within their respective departments.

S.5 Project Leader Shall be responsible for ensuring that the S&IH Professionals and other appropriate members of management are informed of upcoming projects, and that any safety related issues are resolved prior to the project completion per the requirements of this policy.

6. Policy Statements 6.1 Due-Diligence Process

A Due-Diligence study of the prospective acquisition and divestitures shall be conducted to determine strengths and weaknesses of the business, and the impact on safety and environmental requirements.

6.2 Preliminary Environmental, Safety & Health Assessment Questionnaire A Preliminary Environmental, Safety & Health Assessment Questionnaire shall be initiated during the project design/planning phase by the Project Leader and submitted to the primary S&IH Professional at the operating location.

The questionnaire will help ensure that the S&IH and Environmental professionals complete the appropriate risk assessment(s) and associated forms. Assessment information will be forwarded to the project leader for inclusion in the project plan. (See Form-Section 7.1, Appendix I, Preliminary Environmental, Health & Safety Assessment Questionnaire.) 6.2.1 Program Elements shall include the following:

6.2.1.1 What is the basis for the proposed change? 6.2.1.2 What is the time period for the change? 6.2.1.3 What assessments of the pr~posed change will be required? 6.2.1.4 From an Environmental, Health & Safety perspective, what

are the "'things to consider" when making the change? 6.2.1.5 What are the related Environmental, Health & Safety autho-

rization requirements for the proposed change? 6.3 Design for Environment (DfE)

Each operating location shall develop and implement a Management system to ensure that the Design for Environment (DfE} Tool Assessment is performed and documented for all products, packaging, and processes in the research and development phase (all new and changed products).

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6.4 Evaluating Change (Risk Assessment Guidelines)-_Requirements The respective S&IH and Environmental professionals shall work with those responsible for implementing the change to ensure that the appropriate assessments are completed and to determine what actions need to be taken during the design phase. 6.4. l Changes in any one of the following areas can have significant impact

on the safety of associates, the public, the environment, equipment and facilities, and shall require one or more risk analyses to be conducted to determine needs early in the planning process. Identified needs shall be included in the operating location MAP to ensure that corrective actions are brought to closure. 6.4.1.1 New Process Product Development

Development of a new process or a product shall be reviewed for their potential impact on associates and the public relative to exposure, and safe handling of process components and equipment and products.

6.4.1.2 Facility (Construction/Renovation) Project New facility construction and/or renovation to existing facilities shall be reviewed for their potential impact on life safety, environmental aspects, and other related needs prior to occupancy. ·

6.4.1.3 Capital/Non-Capital Project New capital projects shall be reviewed to ensure that safety or environmental issues are identified. While "replacement in kind" (purchase of like equipment) typically does not impact change, capital projects should be evaluated so that advances in safety or environmental technology, or changes in related regulations can be incorporated as part of the project. This includes the purchase of computeri;, other similar equipment, and/or wo~ksll\tiqps to en~Hre that t!te workstations. that w~l be used with the computex:s and other similar equipment is appropriate f9r the job/offic~. '

6·4· 1.4 Existing Product Process Modification Upgrades or m~fications to current operating processes or products such as improvements based on technological advanc~~ents or safer chemical components shall be reviewed f~r therr inherent risk and how the change may affect asso- ciates or existing systems, processes, and/or equipment.

6.4.1.5 External Manufacturing 1 A manufacturer of Lambda products or components sha!l be evaluated for appropriate compliance to 1safety and en~t- ronmenta\ standards. (See Fonns-Section 7.3 Appen~tx ID, Safety & Industrial Hygiene External Manufactunng Checklist, and Section 7 .4, Appendix IV Environmental External Manufacturing Checklist.)

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6.4.1.6 Method~ or Procedures & Production Standards Changes to production ~ethods, procedures, or production standards, shall be reviewed for safety to ensure th t th . rl · th . a e associate pe omung e work is not placed at risk. Documents relative to those methods o~ procedures, such as Job Safety Analysis (~SA), shall be revised and communicated to affected asso- c,iates. The evaluation shall include an Industn'al H . . if h . yg1ene review c eimcals are used and an Ergonomic Job Analysis (EJA) if production standards have been modified.

6.4.1. 7 Product or Equipment Transfer Product and/or equipment transfer from one operating location to another can adversely impact the receiving location in a number of ways. It is imperative that the location transferring the product/equipment obtains the services of the safety and environmental professional(s) at the operating location receiving the product/equipment to communicate anticipated needs or modifications at the receiving location. Operating locations transferring equipment shall either ensure compli- ance of the equipment with applicable standards or communi- cate and document those deficiencies to the receiving location.

6.4.1.8 Business Acquisitions New businesses introduced to the Lambda family of com- panies typjcally are not familiar with Lambda's stringent safety or environmental requirements. It is therefore imper- ative to introduce the new business to Lambda requirements as ~arly as possible after the acquisition.

6.4.1.9 Significant Downsizing/Hiring In periods of significant downsizing or hiring, S&IH shall be included in management discussions in order to anticipate potential impact the change may have on the business.

6.4.1.10 Changes In Management The attitudes, beliefs and values of management, particularly of top management, relative to safety and enviro~ental issues, will set the standard for the operating location. New members of management who have been recruiteq from outside of Lambda must become familiar with their rolb and responsibilities to obtain their support in achieving desired results. Likewise, tho~ who have been promoted from within should reaffinn therr support to the resolution of safety and environmental issues.

6·5 Conducting Risk Analysis-Assessment Formats 6.5.1 Safety Strategy Checklist .

The S&IH professional shall complete the Safety Strategy Checklist f9r all projects associated with _new proce~s/prod~ct development, facility construction or renovations, and capital proJect~. Upon com- pletion, this document shall be reviewed with the proJect leader to

6.6

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identify safety-related needs·early in the process· for incl . F -S ti us1on • Development Phase. (See onn ec on 7 .2, Appendix n 1n the

Strategy Checklist.) . . . ' Safety 65.2 Post Production Safety Qualification Operation Review lhe S&

Professional, who cmr~pleted the EIQ s.afety review, shall com le document, which is then kept on file m the Safety Depllt"h.. P te this

. . ted d . -1.U1ent at th operating location. Observations no unng the original Safi e process shall be documented, 'and · action scheduled for a ety ~Q within 180 days from the date ·bf the · original safety EIQ. ,;-r~view Professional is •responsible for ensuring that the post reviewe &l}f within the prescribed time frame. Action items that have n corrected are to be flagged as "repeat" observations, and conunu: n to the Qualification Coordinator for follow up. cated

6.5.3 Ergo Job Analysis/Analyzer (FJA) This tool shall be used to ensure that modifications made to method procedures; or RE's do not pose an increased risk to the associa~ performing the job and/or task.

6.5.4 Environmental Impact Assessment The Environmental Professional at the operating location where the modifications will be made, will include all environmental aspects of the modifications in the facility's assessment, and will use the results

· of the assessment to implemenr actions in accordance to the facility's Environmental Management System.

6.5.5 Due-Diligence ·rn the event of an acquisition, lease, joint ·venture or divestiture, an audit of the prospective business and · real estate property shall be conducted by appropriate company individuals or a contracted third party. The purpose is to ensure that potential liabilities are identified prior to closure of contracts. The due-diligence report shall be gener- ated by those individuals in order to develop a plan to bring the business under compliance of all Lambda guidelines within pre- scribed . time frames from the date of the acquisition according to the level of requirement as listed in the Lambda Acquisition Guide.

6.5.6 . Design for Environment (DtE) , The concept portion of this tool is to be completed during the Conceplt

· thi too -. ~.tage of new product development. The design portion of s uct , 1s to be completed during the Development Stage of new prodth·s

development. It is the Project Team's responsibility to complete . tool for all new and changed products with ·the assistance and suppo of Environmental Professionals.

Procedure · . 1 6 6 1 At th b · · · , the ProJec

• •• 1 e ~gmrung of the projects design/planni~g phase, & safetY Lefider wdl compl~te th: Preliminary Environmental, ~eal~ D), and ~ssessment Questionnarre (see Form-Section 7.1 Appen~ safetY forward the completed form to the Environmental, Health . pacted Professionals located at the operating location that will be iII1

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by the change. If an Environmental, Health & Safety Professional is not physically located at the operating location, the completed Questionnaire shall be sent to the Environmental, Health & Safety Professional responsible for that location.

6.6.2 Toe Environmental, Health & Safety Professionals, as a minimum, shall contact the Project Leader to discuss the proposed project in order to ascertain the level of evaluation required for the project. Evaluations shall include, but are not limited to, the types of checklists found in the Appendices of this policy.

6.6.3 Assessment information will be documented and forwarded to the Project Leader for inclusion in the project plan.

6.7 Training Management shall be trained in the operating requirements of this policy to ensure its consistent application to business change. Associates involved in operating a new process or technology, or whose safety would otherwise be affected by the change shall be informed of, and trained in, the change prior to its implementation. This training must be documented. 6.7.1 The associate training, at a minimum, shall include:

6.7.1.1 Overview of the changes that will affect them. 6.7.1.2 Any riew or modified requirements governing those changes

[i.e., personal protective equipment (PPE), chemicals, facility/ area .layout, evacuation routes, ergonomic related issues, machine guarding, etc.).

6.7.1.3 A r~view of any 'procedures, i.e., operational and/or safety, i.e., JSA's, process specifications, etc., that have been changed.

6. 7 .1.4 Introduction of any new procedures that are under development in order to gain input from those whom the changes shall ;lffect most.

Z Appendices 7.1 Appendix I-Preliminary Environmental, Health & Safety Assessment

Questionnaire 7.2 Appendix II-Safety Strategy Checklist (Not available) 7.3 Appendix ID-Safety & Industrial Hygiene External Manufacturing

Checklist (Not available) 7,4 Appendix IV-Environmental External Manufacturing Checklist (Not

available) . 7·5 Appendix V-Environmental Impact Assessment Checklist

396 MOC EXAMPLE 10

LAMBDA CORPORATION

PRELIMINARY ENVIRONMENTAL, HEALTH AND SAFETY ASSESSMENT QUESTIONNAIRE

1 • _,

Possibly Triggering a Safety Review

For Intra-Computer Access Enter-Lambda S&IH Appendix I Project leader's name and phone number----'-____ Date ___ _

Enter an "X" in each box that pertains to this project and send the form to S&IH. If an "X'' is entered in any box, a Safety Review by S~IH and En~ironmental Professionals.

1. ____ Project includes purchase of new equipment, iricluding com- puters and associated workstations.

I I ' I I '

2. ____ Modification or addition tq pie existing facility.

Change ,, . . . ;. j • ; 3. ____ To the current energy source~ (electtjc, hydrauli<;:, pneumatic, etc.) 4. ____ To machine guarding 0r electrical ,safety systems. 5 . . ___ , ·1 __ Involves the use ·of a new chemical. . '

.·' l ·1 ,,, l ,.1 6. Involves the use of a biological agent.

• • _, • l

7. __ -_Affects P,ers9n protective equipment requirements 8. __ ___.__ Results in increased noise, vibration, fumes, vapors, radiation,

' _ · te!llperature, etc. . . 9. ____ Results in increased chemical ·storage requirements or increased

chemical utilization . . 10. ____ Affects. manua.J, _materi,aJ handling requirements (weight, force,

frequency, container capacity). 11. ____ Affects exhaust system requirements~ 12. ____ Impacts on Operators work stations, tools, equipment, etc. 13. . Impacts on production procedures; pr9duction' output expecta·

t10ns, or work methods. · ' · 14. ---- Results in an incre.ase or decrease of Operators. · . 15. Results in greater risk.to e~ployee·s who are not operators.

Project Leader signature ---------- For Safety & IH Use Only

16· ---- Safety Assessment Required 17. ---- Ergonomics Job Analyzer Required 18· ---- No Further Required

Signature S&IH ----------- Date _____ _

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LAMBDA CORPORATION 397

RONMENTAL IMPACT ASSESSMENT CHECKLIST eNVI t. ra computer Access, Enter-Lambda S&IF Appendix v For In , AIITha Ar Im acted

h

Air 1mpacts on fa~ili_ty poten~al to emit - Impacts on exist.mg penruts - Requires permit applications - Implications - pollution control/MACT - Other - wastewater

Impacts on existing permits - Requires permit applications = Affects treatment systems

Other

Asbestos _ Fume hoods impacted _ Survey verification required _Continuous sampling required

Other

Drinking Water _ Impacts on cross connections _ Treatment systems impacted _ Sampling plans needed _Other

Community Impacts -LegaVCommunications -Noise -Other Facilities - PM/Calibrations - Water connections/Drains .__ Water conservation .__ Energy connections/Conservation .__ Ventilation connections -- Drawings/Surveys --other

Reporting/Reg. Triggers _FIFRA _TSCA _TRI _CRTK __ p Listed waste __ Risk Management/Planning __ Other

Non-Hazardous or Hazardous Waste __ Segregation __ Collection __ Shipments/Generation rate __ Storage

Other

Chemical Management __ Labeling __ Storage/Grounding __ Segregation/Spill prevention __ Inventory

MSDS needed Pharma/Controlled substances Other

Emergency Response __ Emergency preparedness _ Plans/SPCC plan

Other

EMS __ Management Review __ Commitment and Policy __ Environmental Planning __ Implementation and Operations _ Training (RCRA, DOT)

Other

398 MOC EXAMPLE 10

Environmental Action Plan

Issue Description Follow-up Action Responsible Party Schedule - -

Comments _______________________ _

Date of Action Plan Completion ________ _ Project Leader Sign-Off ________ Date ____ _ Environmental Sign-Off Date ____ _