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

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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.

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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

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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.

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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.

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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.

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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

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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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