Volume 4 :: Issue 4
In This Issue:
the 5 elements...
introducing
rfs2 registration update
esps update
Key environmental dates
Five Year updates
Winter is coming
how to manage waste at
your facitiy
5 Elements of a successful
safety program
E
very company wants their employees working in a safe environment, right? Assuming the answer is “yes”, a successful safety program should be adopted and
include certain fundamental elements. The development, implementation, and sustainability of a successful safety program is no easy task just ask any safety professional. Since all companies are different, it is likely that no one safety program
will work for everyone. However, safety programs generally contain specific universal
concepts. This article reviews five elements that many companies typically include in
their safety programs.
People Oriented
The first element in a successful safety program is that it must be “people centric”. In
order for a safety program to be people oriented there must be: (1) a recognizable culture with beliefs and behaviors that are shared by all team members, (2) a reasonably
high level of employee morale and job satisfaction, (3) trust and open communication
between employees and management, (4) employee involvement and empowerment,
and (5) cooperative working relationships. A people-oriented safety program gives
employees a sense of “buy-in”, actively promotes safety, and accountability. Many
companies have experienced higher levels of morale and job satisfaction when they
engage and empower their employees through their safety programs.
Active Management Commitment
The ERI Exchange is an
informational exchange of ideas
regarding ethanol, grain, and
biodiesel industry safety and
environmental practices and ERI
Solutions Inc.
ERI Solutions Inc.
125 N. First Street
Colwich, KS 67030
The second element in a successful safety program is having an active management commitment to the program. There must be a sense of purpose, identity, and direction when it comes to sustaining a safety program. Active management commitment and support means: (1) written policies must be in place
and enforced, (2) commitment of resources, (3) safety is reaffirmed as a core
value in the organization, (4) accountability of all team members, and (5) performance tracking. The survival of a safety program is directly related to the policies, and accountability of those policies and resources, set forth by management.
Job Design/Ergonomics
The third element is job design and ergonomics. First, let’s take a look at job design.
It doesn’t matter how many safeguards and procedures are purchased or in place if
they are bypassed by employees. As a team, it must be determined why certain safeguards and procedures are being bypassed, and identify ways to guard equipment or
complete a task. As for ergonomics, there are numerous studies that demonstrate the
importance of implementing ergonomics in workplace accident prevention. In addition
to job design and ergonomics, it is important to complete job hazard analysis (JHA).
By completing JHA’s, management, supervisors, and employees will fully understand
the hazards associated with a particular task and ensure safety for all employees.
(continued on page 2)
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(continued from page 1)
Training
The fourth element in a successful and sustainable safety program is training. While training is vital for all team members in an
organization, studies demonstrate that training alone may not be enough. In addition to training, there must be observations,
feedback, and positive reinforcement given to employees. This is why it is important to implement a “traditional” safety program
incoporating a behavior-based safety program. In addition to training and behavioral safety approaches, there must be an effective safety incentive/motivation program established. A safety program that includes incentives and motivation will help keep all
employees involved in safety and continue to reinforce the importance of safety in an organization.
Health Promotion and Disability Management
The fifth element in a sustainable safety program is health promotion and disability management. This is an extremely important
factor in a successful program. In this component of the safety program, there must be an effective return to work and workers
compensation programs, and detailed guidelines on how to respond to injured employees. Numerous studies demonstrate that
successful disability management ensures supervisor participation with regard to employee return-to-work. In addition, there have
been numerous studies conducted that identified and linked safety performance to recreational programs and facilities offered
by employers.
As mentioned, there is no one safety program that will work for everyone. When management and supervisors show active and
continuous support for health and safety within an organization, employees will become more empowered and involved. With cooperation and trusting relationships, together everyone can have a successful health and safety program in order to attain higher
safety excellence.
INTRODUCING INTRODUCING INTRODUCING
Kade McDiffett
Kade graduated from Wichita Area Technical College in 2012 with an Associate’s Degree in Nondestructive Testing. He got started in quality control when he started working at Meadwestvaco Calmar
in Winfield, KS. Kade eventually became a shift supervisor and worked with the lab to improve their
level of quality. After 7 years at Calmar, Kade decided to pursue a degree in Nondestructive Testing.
He has experience with NDT standards used in aviation, such as NAS-410 and SNT-TC-1A. Kade has a
girlfriend, a 3 month old daughter, and lives near Rose Hill, KS.
RFS2 Registration Update Due January 31st
Per 40 CFR Part 80 facilities registered under the Renewable Fuel Standard (RFS) program are required to update their registration every three (3) years. The initial registration under RFS2 occurred in July 2010. EPA finalized an amendment to the RFS2
regulation in January 2012 that set the due date for the registration update as January 31, 2013. As with the initial registration,
the upcoming registration update will need to include an independent third-party engineering review. ERI has partnered up with a
couple Professional Engineers in order to provide this service to the industry. Call Adrien Kogut at (316) 927-4261, or e-mail Adrien
at [email protected] for more information.
There is currently a proposed amendment to 40 CFR Part 80 that would extend the registration update to October 1, 2013. The
proposed amendment was projected to be finalized in November; ERI is paying close attention to this to ensure that our customers
have the most up-to-date information.
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“ESPS: Employee Safety Perception Snapshot” Update
E
RI sent out employee perception surveys to 70 plants. Of the 70 plants,
we experienced only a 30% response
rate. The facilities that did not generate
enough employee responses have been
reminded to complete the surveys to
help ERI understand the safety culture at
each facility.
Of the responses compiled, four reoccurring themes have been identified:
1) there appears to be an unsystematic
approach to a proactive safety culture,
2) employees are looking for safety leadership, 3) there is a disconnect between
defined roles/responsibilities and actions/behaviors, and 4) there is a perception that safety programs and policies are not enforced.
First, there appears to be a disjointed
approach to a proactive safety culture.
Based on employee perceptions, there is
an often inconsistent approach to safety
regarding communication, actions, and
behaviors of all employees.
Secondly, to attain a proactive safety culture in an organization there must be a
collective commitment by leaders and
individuals to emphasize safety as an
overriding priority to complete goals and
other considerations to ensure protection of people and the environment. An
organization must become inspired and
self-motivated to move towards a higher
excellence of safety.
Third, there often appears to be a disconnect between defined roles/responsibilities and actions/behaviors. While 90100% of employee perception responses
state that their roles and responsibilities
have been clearly defined as they pertain
to safety, their perceived actions and behaviors do not match this 90-100%. Figure 1 shows the average percentage of
responses regarding perceived actions
and behaviors to prevent accidents.
Fourth, based on employee perception
responses, employees are looking for
safety leadership and enforcement of
policies and procedures. Employee perceptions measured involvement of management in the safety process regarding
communication (verbal and nonverbal),
appropriate resources, and consistent
accountability of all employees. It appears that many employees view management as able to talk the talk but not
always walk the walk when it comes to
safety. Figures 2 and 3 demonstrate the
average percentage of responses related
to employee perception of safety procedures and policies.
Figure 1
Figure 2
(continued on page 4)
3
(continued from page 3)
Figure 3
Based on the four reoccurring themes,
there are a few ways to address them.
First, management must reiterate safety
is a core value within the organization
and lead by example by actively participating in safety. It is imperative that all
employees understand the importance
of safety throughout the organization.
Secondly, employees at all levels must
have a sense of urgency and enthusiasm
for safety. Along with this enthusiasm
for safety, all employees must also be
engaged. Lastly, as employees become
more engaged and excited for safety,
employees will build self-confidence and
self-efficacy.
KEY ENVIRONMENTAL DATES
Accidents hurt...
...safety doesn’t.
•
•
•
•
January 31, 2012 – RFS2 Registration Update Due to EPA
January 31, 2012 – Annual Alcohol Fuel Report due to TTB
March 1, 2013 – Annual Tier II Reports due to LEPC and Local Responders
March 31, 2013 - Annual Fuel Additive Maufacturer Reports Due to EPA
Five Year Updates - Don’t Get Caught Off Guard!
If your facility started operating in 2008, this next year is a big year for five-year environmental updates. The permits, plans, and
approvals you will want to keep your eye on are NPDES Discharge Permit, Spill Prevention, Controls, and Countermeasures Plan
(SPCC), Risk Management Plan (RMP), and potentially your facility air permit (depending on the type of permit). It is especially
important to know these expiration dates because some permit renewals, like the NPDES Discharge Permit, are due to be submitted 180 days (6 months) prior to the permit expiration date. Another permit to make note of is the Industrial Storm Water General
Permit for your State – these permits typically have a five year life span. You will want to make sure that you are aware of the statespecific expiration date for the Storm Water General Permit.
4
Winter is Coming!
Winter is coming for one and all. This is a good opportunity to look at several items in the plants to make sure everthing is
prepared! See below for some tips for winter.
1. PPE:
a. Is the supply of gloves, hard hat liners, etc, adequate for the season?
b. Do affected personnel have snow claws for their boots?
c. Do affected personnel have baklavas for wind protection?
d. Do affected personnel have adequate coats and bibs?
2. Space Heaters - Are all the heaters being used safe and located safely?
3. Is sidewalk salt, sand or de-ice supplies adequate and distributed in the plant for use?
4. Have all the snow shovels been distributed for service?
5. Is the snow-blower ready for the season?
a. Is there adequate gas onsite?
6. Is there a checklist for inspecting emergency and seldom used exit doors to ensure they can be opened?
7. Is there a checklist for inspecting areas where overhanging ice, snow and roof slide-offs can occur?
8. Have all rolling stock been tested for anti-freeze protection? (This is also a good time to remind personnel to prepare personal
vehicles!)
9. Is insulation on critical lines intact and in good repair (not mashed down from foot traffic, etc.)?
10. Are all manway insulation covers back on the vessel?
11. Are the heat-trace systems ready for use in the plant?
NOTE: Are the heat trace systems wired direct without extension cords?
Obviously, this is not a complete list, but hopefully with this reminder you will get your own list out and start working on it!
This is probably a good time to have a toolbox talk on personal safety. Remind employees to allow extra time to get to work
and to stock their personal vehicles with emergency cold weather survival items! Here are a few tips and reminders that can
help as winter progresses and we start dealing with icy and cold working conditions.
• Employees who regularly work outside may want to purchase winter boots that are insulated or ½ size larger to allow for extra
pair of wool socks.
• Perspiration may also be a factor for footwear and clothing while working in cold weather. An extra pair of boots, socks and
clothing should be kept in their vehicle or locker to change into should they become wet. Footwear and clothing should be
checked regularly, especially during breaks and lunch. Dry clothing and footwear are important in protecting employees from
physical effects of working in the cold.
• Space Heaters: People tend to use personal heaters under their desk or in their offices to supplement the heat for comfort.
Are all these heaters safe? A full inspection may be in order. Some people put these in the leg opening under their desks.
○○ Are the spaces clear of combustible materials to prevent a fire?
○○ Are the units UL approved?
NOTE: Heaters with exposed electric heat resistant wires cannot be used in rail and truck loadings and unloading areas.
○○ Do they have a 3 prong plug with the ground prong intact?
○○ Are they located safely?
○○ Do they have an automatic tip-shutoff?
This is good information for employees to use to inspect home space heaters as well!
• Exit doors: Some doors are not used regularly, but they must be maintained as emergency exits. Snow drifts and Ice can build
up outside the door, blocking use. Regularly inspect all doors to ensure they can be used. Also, placement of ice blades is
recommended to remove ice buildup.
• Ice overhangs: Regularly inspect all areas along walkways, over doorways, etc. Ice can build up and create a hazard for foot
traffic and vehicles. Do not overlook areas where snow and ice can build up on roof areas that are constructed of smooth
steel sheet panels. Ice and snow can build up and slide off without warning. We have reported incidents of vehicles parked
next to buildings being damaged from blocks of ice and snow falling. Overhangs and snow slides can also occur on tanks!
NOTE: Ice and snow will become slicker when temperatures are near just freezing, so a warm period may be more hazardous! Schedule outside
activities where footing is best. Wearing snow claws in slick areas may prevent a nasty fall!
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How to Manage Hazardous Waste at Your Facility
W
hile hazardous waste management often takes a back burner to daily plant operations, it is vital that plant
personnel take hazardous waste management seriously. Most every ethanol plant can qualify for Conditionally Exempt Small Quantity Generator (CESQG) status if they have properly classified and managed their waste as
hazardous or nonhazardous. However, a single failure to properly classify and quantify all plant waste can generate
an automatic violation, and may bump a facility into a higher level of generator status where waste management
requirements automatically become more stringent.
What does an ethanol plant need to do?
First, characterize all waste stored onsite.
A hazardous waste is anything that exhibits potentially dangerous properties, and is intended to be discarded. Examples of hazardous wastes can include solvents and COD vials. If a facility intends to discard a waste then that waste
must be characterized. Wastes are classified as characteristic or listed hazardous waste, determined by the EPA lists
of hazardous wastes. Each waste must be given its appropriate characterization code prior to disposal offsite.
Second, total the amount of hazardous waste generated each month.
Each facility should maintain a running total on how much hazardous waste is generated on a monthly basis. One
can’t demonstrate they are a CESQG unless they know how much waste is generated. CESQG totals have to be less
than 220 pounds of hazardous waste generation in one month. However, there are exemptions that allow hazardous materials to be recycled, therefore, not impacting hazardous waste totals. If hazardous waste is generated and
exceeds 220 lbs/month, the plant automatically loses their CESQG status, and has to then comply with the requirements as a larger quantity generator. It is important to educate plant personnel on hazardous waste, as generator
status can change simply by incorrectly disposing of something as simple as used oil or a can or paint.
Third, determine if the facility meets CESQG thresholds or not.
If a facility is properly classifying and quantifying their plant’s waste, more than likely that facility will classify as an
exempt source. Characterizing and quantifying hazardous waste will help every facility stay below the set thresholds.
Waste classification and management criteria, when followed correctly, will help keep an ethanol plant as a CESQG,
and ultimately reduce noncompliance exposure. If CESQG levels are exceeded, the plant automatically becomes a
Small Quantity Generator (SQG) or Large Quantity Generator (LQG), depending on the amount of waste generated
and/or disposed. As a SQG or LQG generator of hazardous waste, a facility must conduct training related to hazardous waste management, maintain additional records, and be subject to annual reporting with potential fees. Expectations and obligations increase at higher levels of generator status. ERI recommends implementing a Hazardous
Waste Procedure including a method of characterizing and quantifying hazardous waste on a monthly basis to help
your facility establish policies and follow regulations related to hazardous waste. ERI has a template Hazardous
Waste Characterization Plan that can help your facility satisfy these requirements.
Happy
Holidays
(and safe)
ERI You!
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