Safety Procedures and Risk Assessments in NORMS COP Documentation

This document outlines the safety procedures and risk assessments that should be included in a company's NORMS Code of Practice (COP) documentation. It is based on industry best practices and regulatory requirements to ensure a safe working environment.

Risk Assessment Procedures

Risk assessment is a critical component of any safety program. It involves identifying potential hazards, evaluating the likelihood and severity of potential incidents, and implementing control measures to mitigate those risks. The following steps should be included in the risk assessment process:

1. Hazard Identification: Systematically identify potential hazards associated with all activities, equipment, and substances used in the workplace. This includes physical hazards, chemical hazards, biological hazards, and ergonomic hazards.
2. Risk Evaluation: Evaluate the severity of potential injuries or illnesses that could result from each identified hazard, as well as the likelihood of those events occurring. This evaluation should consider factors such as the number of employees exposed, the frequency of exposure, and the effectiveness of existing control measures.
3. Control Measures: Implement appropriate control measures to eliminate or minimize identified risks. The hierarchy of controls should be followed, prioritizing elimination, substitution, engineering controls, administrative controls, and personal protective equipment (PPE).
4. Documentation: Document all steps of the risk assessment process, including hazard identification, risk evaluation, and control measures implemented. This documentation should be readily available to all employees and updated regularly.
5. Review and Revision: Regularly review and revise risk assessments to ensure they remain current and effective. This review should occur whenever there are changes in processes, equipment, or substances used in the workplace, or after any incident or near-miss event.

Safety Procedures

The NORMS COP documentation should outline specific safety procedures for all activities performed in the workplace. These procedures should be based on the risk assessments and designed to minimize the risk of injury or illness. Key areas to address include:

1. Operating Procedures: Detailed instructions on how to perform tasks safely, including step-by-step guidance, safety precautions, and emergency procedures. Operating procedures should be technically accurate, understandable to employees, and revised periodically to ensure they reflect current safe operations. The process safety information package is to be used as a resource to better assure that the operating procedures and practices are consistent with the known hazards of the chemicals in the process and that the operating parameters are accurate. Operating procedures should be reviewed by engineering staff and operating personnel to ensure that they are accurate and provide practical instructions on how to actually carry out job duties safely.
2. Lockout/Tagout Procedures: Procedures for de-energizing equipment and preventing accidental startup during maintenance or repair. These procedures should comply with established lockout/tagout standards and include specific steps for applying and removing locks and tags.
3. Confined Space Entry Procedures: Procedures for safely entering and working in confined spaces, including atmospheric testing, ventilation, and rescue plans. These procedures should address the identification of confined spaces, hazards, requirements before confined space is entered and requirements before hazardous confined space is entered.
4. Emergency Procedures: Plans for responding to various emergency situations, such as fires, chemical releases, and medical emergencies. These plans should include evacuation routes, alarm systems, and contact information for emergency responders. Each employer must address what actions employees are to take when there is an unwanted release of highly hazardous chemicals. Employers at a minimum must have an emergency action plan which will facilitate the prompt evacuation of employees when an unwanted release of highly hazardous chemical.
5. Hazardous Materials Handling: Procedures for safely handling, storing, and disposing of hazardous materials. These procedures should include information on proper labeling, personal protective equipment, and spill response. Employers need to select how many different emergency preparedness or tertiary lines of defense they plan to have and then develop the necessary plans and procedures, and appropriately train employees in their emergency duties and responsibilities and then implement these lines of defense.

Employee Training

Comprehensive employee training is essential to ensure that all workers understand the safety procedures and can perform their jobs safely. The NORMS COP documentation should outline the requirements for employee training, including:

1. Initial Training: All new employees should receive comprehensive safety training before beginning work. This training should cover general safety rules, hazard communication, emergency procedures, and job-specific safety procedures.
2. Job-Specific Training: Employees should receive training on the specific hazards and safety procedures associated with their job tasks. This training should be tailored to the individual's role and responsibilities.
3. Refresher Training: Regular refresher training should be provided to all employees to reinforce safety knowledge and address any changes in procedures or regulations. Careful consideration must be given to assure that employees including maintenance and contract employees receive current and updated training. For example, if changes are made to a process, impacted employees must be trained in the changes and understand the effects of the changes on their job tasks (e.g., any new operating procedures pertinent to their tasks).
4. Documentation: All training should be documented, including the date, topics covered, and names of attendees. Training records should be maintained and readily available for review.

Compliance Audits

Regular compliance audits are necessary to verify that the safety procedures are being followed and that the safety program is effective. The NORMS COP documentation should outline the procedures for conducting compliance audits, including:

1. Audit Frequency: Audits should be conducted at regular intervals, such as annually or semi-annually, to ensure ongoing compliance.
2. Audit Scope: Audits should cover all aspects of the safety program, including risk assessments, safety procedures, training, and recordkeeping.
3. Audit Team: The audit team should consist of individuals with the knowledge and experience to evaluate the effectiveness of the safety program. An effective audit includes a review of the relevant documentation and process safety information, inspection of the physical facilities, and interviews with all levels of plant personnel.
4. Corrective Actions: Any deficiencies identified during the audit should be promptly addressed with appropriate corrective actions. Corrective action is one of the most important parts of the audit. It includes not only addressing the identified deficiencies, but also planning, follow-up, and documentation. The corrective action process normally begins with a management review of the audit findings.
5. Documentation: All audit findings and corrective actions should be documented and tracked to ensure completion.

Incident Investigation

A thorough incident investigation process is crucial for identifying the root causes of accidents and preventing future occurrences. The NORMS COP documentation should outline the procedures for incident investigation, including:

1. Reporting: All incidents, including near misses, should be reported promptly to allow for timely investigation.
2. Investigation Team: A team should be assembled to investigate incidents, including individuals with relevant knowledge and experience. Employers need to develop in-house capability to investigate incidents that occur in their facilities. A team needs to be assembled by the employer and trained in the techniques of investigation including how to conduct interviews of witnesses, needed documentation and report writing.
3. Root Cause Analysis: The investigation should focus on identifying the root causes of the incident, rather than simply assigning blame. The focus of the investigation should be to obtain facts, and not to place blame.
4. Corrective Actions: Corrective actions should be implemented to address the root causes of the incident and prevent similar events from occurring in the future.
5. Documentation: All incident investigations, findings, and corrective actions should be documented and tracked.

Emergency Preparedness

The NORMS COP documentation should include a comprehensive emergency preparedness plan that addresses potential emergencies and outlines the steps to be taken to protect employees and the environment. Key elements of the emergency preparedness plan include:

1. Emergency Action Plan: A written plan that outlines the procedures for responding to various emergencies, including evacuation routes, alarm systems, and communication protocols. Employers at a minimum must have an emergency action plan which will facilitate the prompt evacuation of employees when an unwanted release of highly hazardous chemical.
2. Emergency Response Team: A trained team of employees who are responsible for responding to emergencies. If the employer wishes to use plant personnel such as a fire brigade, spill control team, a hazardous materials team, or use employees to render aid to those in the immediate release area and control or mitigate the incident, these actions are covered by 1926.65, the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard.
3. Communication: Procedures for communicating with employees, emergency responders, and the public during an emergency. One effective way for medium to large facilities to enhance coordination and communication during emergencies for on plant operations and with local community organizations is for employers to establish and equip an emergency control center.
4. Drills and Exercises: Regular drills and exercises to test the effectiveness of the emergency preparedness plan. Drills, training exercises, or simulations with the local community emergency response planners and responder organizations is one means to obtain better preparedness.

Hazardous Substances

The NORMS COP documentation should include guidelines for managing hazardous substances in the workplace to protect employees from exposure and ensure compliance with safety regulations. Key aspects of hazardous substance management include:

1. Inventory: Maintain a comprehensive inventory of all hazardous substances present in the workplace.
2. Safety Data Sheets (SDS): Ensure that SDSs are readily available for all hazardous substances and that employees are trained on how to access and interpret them. Training conducted in compliance with 1926.59, the Hazard Communication standard, will help employees to be more knowledgeable about the chemicals they work with as well as familiarize them with reading and understanding SDS.
3. Labeling: Ensure that all hazardous substances are properly labeled with appropriate warnings and hazard information.
4. Storage: Store hazardous substances in accordance with manufacturer's instructions and applicable regulations. Storage of hazardous substances should adhere to guidelines regarding permitted quantities and incompatible substances.
5. Personal Protective Equipment (PPE): Provide appropriate PPE to employees who handle hazardous substances and ensure that they are trained on how to use it correctly. Selection, use, and maintenance of PPE are critical for worker safety.
6. Spill Control: Develop and implement procedures for containing and cleaning up spills of hazardous substances. Preplanning for handling incidental releases for minor emergencies in the process area needs to be done, appropriate equipment for the hazards must be provided, and training conducted for those employees who will perform the emergency work before they respond to handle an actual release.

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