HomeMy WebLinkAboutMINUTES - 02112003 - C.84 C.84
THE BOARD OF SUPERVISORS OF
CONTRA COSTA COUNTY, CALIFORNIA
Adopted this Order on February 11, 2003 by the following vote:
AYES: Supervisors Gioia, Uilkema, Glover and DeSaulnier
NOES: None
ABSENT: Supervisor Gerber
ABSTAIN: None
RE: General Chemical
The Board of Supervisors ACCEPTED the correspondence from General
Chemical dated January 24, 2003, as requested by the Board on January 14,
2003.
I hereby certify that this is a true and correct copy of
an action taken and entered on the minutes of the
Board of Supervisors on the date shown.
Attested:February 11,2003
John Sweeten,Clerk of the Board
of Supervisors and County Administrator
By n
Duty
ene I
J henRECEIVE
,I cil JAN 2 a 2003
&3
HAZMarvr ^ C
. SrA ►A� CONTRA COSTA HEALTH
(D US �LtAr HS HAZARDOUS MATERIALS
525 Castro Street
Richmond, CA 94801
Tel: 510232.7193
January 24,2003
Fax: 510.232.7629
Contra Costa Health Services
Attn: Lewis G.Pascalli Jr.Esq.
4333 Pacheco Boulevard
Martinez,CA.94553
Dear Director Pascalli:
On January 14,2003, 1 made a brief presentation to the Contra Costa County Board of Supervisors as
part of the Safety Evaluation Report on the General Chemical Richmond facility. At that time I
committed to providing a copy of our action item pian complete with recommendations,actions planned
to address the recommendation, and target dates. Attached to this cover letter please find an updated
copy of our Action Item Plan for your information and use.
I indicated in my presentation that 20%of the recommendations are implemented. Those action items
are the shaded items in the plan and include the completion date. There is activity underway on every
item at this time. Some by the very nature of the action item require more time due to planning,
engineering or employee involvement to implement. We will expedite all of these items to complete
them in a timely fashion. I recommend we use this format, along with any additional dialog deemed
appropriate,to communicate progress on a quarterly basis.
The public review of the Safety Evaluation Report did generate some media attention. The West
County Times and The San Francisco Chronicle both covered the public process with articles
published during the following two days. The media coverage highlighted the historical events and
findings from the report and offered limited examples of the positives identified in the report. I did not
think the coverage adequately recognized the progress made at our facility. I responded to the
published article through letters to the editor. It was a challenge to discuss my topic in 200 words or
less. I have attached a copy of those letters to this cover for your information and use.
The General Chemical Richmond facility is fortunate to participate with an active Community Advisory
Panel (CAP) to promote dialog between the community and company employees. The CAP
suggested a newsletter highlighting facility activity would be a good technique for outreach to
individuals who live or work near the plant. The first issue was distributed in December 2002 to 2100
business and home addresses within a one-mile radius of the plant. A copy of the newsletter is
attached for your information and use.
A package of this information is also being sent to all Board of Supervisor members and key county
officials involved in the process. If you should have any questions please feel free to call me at 510-
232-7193 ext.226.
Sincerely,
Larry P. Landry
Plant Manager—General Chemical Richmond Works
General Chemical-Richmond Warks Safety Evaluation Action Item Flan
Update:January 23,2003
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requirement for reviewing
prior incidents,but the
documentation during these
revalidation needs to be
improved. Check with RRS
Engineering to determine if
recent PHA revalidations can
Modify the RMP/Cal ARP be revised to include incidents
Procedures covering PHAs to that were addressed in the
include a requirement that each PHA. if RRS Engineering
PHA contain a list of the past cannot modify the existing
The PHAs do not include incidents addressed in the PHA, PHA revalidations, 6/30/03 or
sufficient documentation to and that the PHA documentation documentation will be during the next
show how past incidents specifically identify where each improved during the next revalidations i
.i.l were addressed in the PHA. incident was addressed. Medium revalidations. 7akonczuk 2006-07
Develop a written procedure that
covers the development,revision,
and certification of operating
procedures.This procedure should
address who is responsible for the
development and revisions to
operating procedures,who is The Production Foreman will
There is no written responsible for approving any new develop a procedure that will
procedure that covers the or revised operating procedures, be included in the SOP manual
development,revisions,and and who is responsible for the that covers the development,
certification ofoperating annual certification of the revisions and certification of
2.1 i procedures. operating procedures. Medium operating procedures. Sampson 1131/03
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A review of incident and
near-miss reports for the
years 2000,2001,and 2002
indicate that near misses are A near miss reporting program
being under reported.For will be developed and added to
example in the year 2001, Provide additional training to the the Safety Manual and will
only 4 of the 29 reported workers on the importance of include incentive for reporting
incidents were near misses reporting near misses.Develop a near misses. Training will be
and this reporting is much near-miss reporting program that conducted. An analysis of nes
lower than would normally provides incentives for staff to misses will be included in the
be expected for this type of report near misses.See also 2.3.27 monthly safety council
2.1.10 facility. and 2.3.28. High meetings. Landry/Jakonczuk 3!31103
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All supervisors will participate
in an incident investigation
training course. The course
will be conducted by General
Chemical or a third-party
consultant. The course will
include emphasis on root cause
Develop an incident investigator analysis,who is responsible for
training course,and require that developing corrective action
There is no documented this be taken before an individual items across all like
training course for incident may conduct an incident equiment/systems at the
2.1.14 investigation team leaders. investigation. Medium facility. Jakonezuk 4/30/03
All supervisors will participate
in an incident investigation
Develop a training course for training course. The course
The incident investigation incident investigation team leaders will be conducted by General
procedure does not indicate with an emphasis on GCRW's Chemical or a third-party
who is qualified to conduct procedure for root cause analysis. consultant. The course will
incident investigations,and The training course should also include emphasis on root cause
incident investigators do not cover who is responsible for analysis,who is responsible for
receive training in the developing recommendations for developing corrective action
incident investigation applying incident investigation items across all like
technique and how to action items across all like equiment/systems at the
2.1.15 identify root causes. equipment/systems at the facility. Low facility. Jakonczuk 4/30/03
he work order torm
generated by the Maximo Modify the work order form The work order system will be
system does not show who generated by the Maximo system to modified to include the person
requested the work to be include the person who requested who requested the work to be
2.1.16 performed. the work be performed. Low done. Mills 3/31/03
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General Chemical-Richmond Works Safety Evaluation Action Item Man
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Establish a Document Control
Procedure for managing the
development review certification
and distribution of safety program
Several safety management documents including the plant
programs lack adequate rules,plant policies,training
document control to ensure system,job descriptions,etc.This The document control
that they are developed, procedure should assure that all procedure that is currently use
implemented,revised and safety management system for ISO will be utilized for
distributed in an effective documents are current,consistent, Emergency Response and
2.1.19, manner. and accurate. Medium Safety procedures. Jakonczuk 4/30/03
The majority of displays in
the control room are It is recommended that General
comprised of very old Chemical hire a qualified human
technology whose factors consultant to perform a
interpretability is non- cognitive task analysis(CTA)of
intuitive,particularly for control room functions as they
inexperienced Operators and relate to display design and use.
for all Operators under upset The output of a CTA is important General Chemical will utilize a
or stressful conditions. in identifying human performance consultant to perform a
There is a high degree of bottlenecks(e.g.,limits in the cognitive task analysis(CTA)
inconsistency among display interpretability of displays under on the existing control panel,
formats,and a lack of routine and/or upset conditions) in conjunction with the
displays that provide a that exist with the current system. installation of a new
quick,overall,"at-a-glance" Additionally,a CTA can provide Distributed Control System
summary of the state of general design and implementation (DCS)that will replace the
plant processes.The mimic guidelines for improved displays existing control room displays.
displays that are available based on the results of the CTA Conducting the CTA and
for the CP plant are good, itself,as well as general guidance installing a DCS will also
particularly at providing at-a from the human factors display address all alarm issues. The
glance summaries of CP knowledge base.The potential installation of a DCS will
processes.however,similar benefit of implementing a involve significant additional
displays are not available Distributed Control System(DCS) training to all operations CTA by
for other processes should also be considered in the personnel to ensure 9/30/03;DCS
2.2.1 ffhroughout the facility. CTA. Medium understanding of the system. I Waxmonsky by 12/31/04
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Senior management and It is recommend that the new
training personnel have not permanent Plant Manager(when
had sufficient training or appointed),the Operations
background in human Superintendent,and the EHS
factors and ergonomics. Manager receive general
Their lack of training in background training in the areas of
these areas prevents them human factors engineering and
from being able to ergonomics.Short courses on these
adequately train plant topics are generally offered by(1)
personnel in these areas and human factors and ergonomics
prevents them from being consultants,(2)local universities, The Plant Manager,EHS
sufficiently aware of human and(3)workshop presenters at Manager and Operations
factors and ergonomic human factors and ergonomics Superintendent will attend a
safety issues throughout the conferences(e.g.,National course on human factors Landry/Jakonczuk/
2.2.2 facility. Ergonomics Conference). Low engineering and ergonomics. hitter 6/30/03
Human factors and human It is recommended that a segment
performance issues are not on human factors and human The existing ergonomics
adequately covered as part performance principles and training program will he
of training for plant guidelines be added to the safety enhanced and will include
personnel.The majority of training curriculum.Additionally, issues on human factors and
plant personnel have had no the safety walkthrough that human performance. The self-
exposure to concepts related accompanies safety training audit program will be amended
to causes of human error, sessions should also incorporate the to include the identification of
ergonomic risk factors for identification of human factors and human factors and human
2.2.3 injury,etc. ergonomic risk factors. Low performance issues. Lane 2/28/03
Control room alarms lack
sufficient discriminability
and are not sufficiently
prioritized.For instance,
when Operators are outside
the control room and hear
an alarm it is generally not General Chemical will utilize a
possible to identify its consultant to perform a
source without returning to cognitive task analysis(CTA)
the control room or on the existing control panel,
communicating with in conjunction with the
someone in the control installation of a new
room.Additionally,once As part of the CTA recommended Distributed Control System
alarms are acknowledged in(1)above,an analysis of the (DCS)that will replace the
they will not repeatedly current design and operation of existing control room displays.
sound even if Operators fail control room alarms should be Conducting the CTA and
to address the underlying conducted.This analysis should installing a DCS will also
condition.This could cause address current problems with address all alarm issues. The
an Operator to forget about alarm discriminability and installation of a DCS will
an alarm condition should prioritization,and should result in a involve significant additional
he/she become preoccupied set of guidelines and training to all operations CTA by
with another existing recommendations for an improved, personnel to ensure 9/30/03;DCS
2.2.4 situation. reconfigured alarm system. High Junderstanding of the system. Waxmonsky by 12/31/04
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General Chemical-Richmond Works Safety Evaluation Action Item Plan
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Simulations and drills should
become a more central element of
GCRW's approach to safety
The current approach to training.Drills should focus on
training relies heavily on emergency procedures and
classroom-style instruction emergency response,enabling
and testing,as well as on- personnel to practice and refine
the job training.however, essential skills and behaviors
simulations and drills are needed to adequately cope with
not used to full advantage as emergency conditions.Drills often
training methods.While have the added benefit of
minimal use of these illuminating shortcomings in
techniques has recently been current emergency procedures so
introduced in the facility, that better procedures can then be A comprehensive training
they are not sufficiently adopted.Simulations(e.g.,desktop, program will be developed to
employed.Additionally, PC-based simulations)should be include emergency operating
there appears to be a lack of used to provide Operators with the procedures and emergency
awareness among managers opportunity to familiarize response actions. A PC-based
of modem training themselves with plant process simulator or other
technologies such as characteristics as they vary due to enhancements will be
desktop computer-based the presence of various upset and considered to simulate
2.2.5 simulation tools. non-routine conditions. Medium emergencies. Waxmonsky/Ritter 12/31/03
There is insufficient General Chemical should
emphasis placed on reward investigate methods for increasing
and positive reinforcement the use of reward and positive
as a means of increasing reinforcement to promote effective
good safety behaviors and safety behaviors among plant General Chemical will develop
practices.While discipline personnel.The reward does not a safety incentive program that
for unsafe practices appears necessarily need to be money will focus on positive rewards.
to be well enforced,there is (General Chemical already Rewards will be based on the
no formal arrangement for includes a monetary reward as part number of near misses
plant personnel to be of its 3-P program),but could reported,unsafe observations
rewarded(e.g.,with letters involve letters of recognition,"Safe and safety suggestions. Each
of commendation,awards, Employee of the employee's status will be
informal positive statements Month/Quarter/Yeae'awards,and posted and included in the
from management,etc.)for even informal"attaboys"from monthly safety council
good safety decisions and plant management in the presence meetings to encourage friendly
2.2.6 practices. of other plant personnel. Medium competition. Landry/.lakonczuk 3/31/03
There is little or no"team
concept"among plant
Operators,perhaps primarily
due to the fact that the
current shift structure
prevents the formation of
cohesive teams(i.e.,
Operators do not work with
the same individuals on a
consistent basis).This
prevents Operators from
forming the type of As part of the next union collective
teamwork bonds that bargaining effort,GCRW should
promote a sense of caring seek a change in the current shift
and awareness of other team structure to enable the same people Modification of the shift
members'strengths, to work together on the same team schedule will be negotiated
2.2.7 weaknesses,habits,etc. more consistently.See also 2.3.6 High during the next union contract. Landry 6/30/03
It is recommended that GCRW
develop a new vision for the safety
program and a strategy for attaining
the vision.This visioning process
should incorporate the following
elements:
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General Chemical-Richmond Works Safety Evaluation Action Item Plan
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guide the initiative.The team
should include:senior
managers who are fully
committed to implementing
the vision with sufficient
authority and influence to
provide resources and
develop policy;plant
management;first line
supervisors;representatives
from GCRW Operations and
Maintenance;and represents
labor.All team members
should be recognized as
leaders,having respect from
their colleagues and workers
for their ability to
successfully implement new
ideas.
Develop a compelling
safety vision statement,and a
concise strategy for how the
vision will be accomplished.
The guiding team should
consider existing programs
within General Chemical and
their potential for
contributing towards the new
vision,but the team should
also have the freedom to
develop completely new
ideas that will likely appeal t
the GCRW workers,and
provide the inspiration for
gaining broad-based support.
The strategy should lay out a
logic for achieving the vision,
including preliminary plans,
budgets and schedules.
Offsite meetings could help
to provide an environment
conducive to this type of
creative process.
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General Chemical-Richmond Works Safety Evaluation Action Item Plan
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for communicating the vision
with all employees at GCRW.
This framework needs to be
simple,effective,and include
strategies for addressing the
resistance to change that is
likely to be encountered.The
new vision and strategy
should address the risk-taking
behaviors and"obstacles to
safety"that are evident in the
existing culture.Through the
application of a clear vision
statement and consistent
communication of the values
inherent in the vision,the
new initiative should help the
organization address these
barriers,and to address the
obstacles evident in the
existing culture.This may be
achieved using a wide range
of communications
approaches(persuasive
communication,role
modeling,expectancy,
coercion,rewards,structural
rearrangement,etc.).These
"methods of influence"can
be very effective in dealing
with the"multiple realities"
Identify needs for
training and ways to
empower the work force to
increase performance
standards and to allow them
to actively participate in the
new safety initiatives.During
the change process,there is
likely to be a need for
training to provide workers
with new skills and attitudes
for assuming the
responsibilities and behaviors
that are called for in the new
vision.Of particular
importance with respect to
GCRW is the need for
workers to develop team
skills,team goals and a sense
of purpose as one unit.
Managers and supervisors
would likely benefit from
leadership training and skills
development.
Establish a sense of
urgency by emphasizing the
critical importance of this
initiative for moving beyond A Safety Vision Team will be
the current realm of problem developed that will include
solving and"fire fighting," personnel from management,
and establishing self-directed supervisors,engineers,
teams responsible for operators and mechanics. The
implementing broad-based team will be tasked with
safety programs. building on the Cornorate 3P
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General Chemical-Richmond Works Safety Evaluation Action Item Plan
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resource and financial (People,Performance and
systems and to make sure Practices)program. A key
they are fully aligned with the element will be to develop a
new vision.This should vision that will be
involve goal setting for communicated to employees
individuals and groups; on a regular basis so that it will
review and revision of the be embraced. As a starting
performance appraisals,job point for the richmond Works
descriptions,and how staff safety vision,the 3P elements
are being hired;review of will be expanded into a policy
how resources are allocated statement for richmond
and what reward systems are Works. PEOPLE will be
in place.The required skill expanded to include:(1)The
sets for new hires should be Safety Incentive Program
considered to be sure that mentioned in 2.2.6;(2)Annual
attitude and leadership performance evaluations for all
capabilities are considered as employees,with a section
well as technical skills. dedicated to safety;and(3)
Quarterly Plant Manager
As the safety initiative progresses, meetings to address the plant's
Managers and workers at the intent is to establish a culture safety performance and address
GCRW do not have a clear that is fully committed to safety at future goals and activities.
vision for the facility health every level of the organization, Individuals will be recognized
and safety program.Safety with every participant working by the Plant Manager or others
slogans and safety messages towards the same vision of safety. in the presence of his/her peers
do not provide a persuasive As peoples'level of trust grows to acknowledge good safety
and compelling vision of the over time,so also will the level of performers. PERFORMANCE
safety objectives for the participation.This approach should will be expanded to include:
plant,and there is no allow employees to identify better (1)A compilation of the
consistent communication ways for achieving superior safety beading and Lagging
2.3.1 lof a safety vision. performance. High Indicators by the EHS Manager Landry/Jakonezuk 3/31/03
There is little awareness
among workers of the full
scope of the General
Chemical 3P Program,and
the importance of 3P
participation has not been
effectively conveyed to
workers.Operators and General Chemical should promote
maintenance personnel are greater awareness of its 3-P safety
aware that they can receive program.This can be accomplished
a$50 quarterly bonus if no by disseminating printed material
recordable injuries occur to plant personnel describing the
during that time period,but attributes of the program,and/or by
are almost unanimously featuring the program as a key
unaware of any other element of monthly safety training
2.3.2 features of the program. sessions.See also See 2.3.1. Medium See 2.3.1 above Landry/Jakonczuk 3/31/03
See 2.3.1 above. Also,safety
suggestion boxes will be added
Management has not throughout the plant to allow
demonstrated to workers a employees to bring up safety
convincing ability to act concerns anonymously. These
quickly over health and safety suggestions will be
safety concerns and tracked in the monthly safety
2.3.3 suggestions. See 2.3.1 High council meetings. Landry/Jakonczuk 3/31/03
Workers perceive that some
supervisors and managers
appear to be uncertain as to
what is needed to ensure
L12.L safety and health. See 2.3.1 High See 2.3.1 above Landry/Jakonczuk 3/31/03
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General Chemical-Richmond Works Safety Evaluation Action Item Plan
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Some managers perceive
that supervisors may not be
devoting sufficient effort to
health and safety,and some
workers think supervisors
may not be good at
2.3.5 detecting unsafe behaviors. See 2.3.1 High See 2.3.1 above Landry/Jakonczuk 3/31/03
appeared to be an attitude o
"resigned acceptance"as to
the level of safety
performance that is possible
at GCRW.Workmates"
influence and peer pressure
within the Operations
Department do not appear to
be conducive to team
building and working as a
group towards a shared
vision of safety.The
influence of fellow workers
(including first line
supervision)in the
Maintenance Department
appears to foster an attitude
in which workers are
reluctant to accept much
responsibility for raising
safety performance
standards.
A training program will be
The changes at management Consider giving workers training to developed that will help
level and the limited help them learn the new behaviors, employees recognize unsafe
expenditures on preventive skills and attitudes needed to behaviors. This training will
maintenance at GCRW in increase their personal be conducted annually. In
the past have likely effectiveness.Conduct leadership addition,supervisors will
contributed to this attitude training for workers and line attend leadership or team
among the workers. supervisors.See also 2.3.1 and building training to foster a
2.3.6 2.2.7 High team approach to safety. Landry/Jakonezuk 6/30/03
Develop a set of leading indicators
for safety metrics to complement
the lagging indicators currently
used.Examples of leading metrics
include safety and training activity
hours per person;numbers of
audits/inspections,safety meetings,
training courses,tool-box meetings,
safety suggestions,near misses Leading indicators for safety
Safety metrics have not reported,etc.Offsite injuries(of metrics will be developed and
been developed and adopted workers)are also used by some will include the number of
for leading indicators of companies as an indicator of safety suggestions,near miss
safety performance.The cultural attitudes to safety.Targets reports,safety observations
lagging indicators used by should be set for all of these issued and the status of the
management do not convey metrics,and progress should be safety incentive program.
information to reflect recent measured against the targets.At- Goals for each will be set. A
progress being made with risk behaviors can also be summary report will be added
regard to the safety measured and tracked against to the monthly safety council
2.3.7 program. targets. High meeting and will be posted. Jakonczuk 3/31/03
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General Chemical-Richmond Works Safety Evaluation Action Item Pian
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evemop a list or leacang an ec .3. vo. so, aggmg
lagging safety performance indicators for safety metrics
indicators that will be shared with will be developed and will
employees on a regular basis(e g., include first aid injuries,
monthly).The statistics should be recordable injuries,total case
presented in a suitable format(e.g. incident rates,Level 0,1,2 and
Safety performance metrics using charts and graphs)to present 3 incidents,number of
and safety performance trends and progress,and distributed Corporate audit findings,
progress are not shared to all GCRW employees.See also regulatory violation notices
2.3.8 widely with hourly workers. 2.3.7 High and fines. Jakonczuk 3131103
include this as an item for
negotiation in the next union
contract renewal.The policy
development should have worker
input,and all workers should be
given an orientation of the new
policy to make it clear when and A disciplinary policy will be
Some workers appeared to how discipline will be used developed with the aid of
be apprehensive about depending on the severity of the Corporate and local human
making mistakes for fear of misdemeanor.Ensure that this resources personnel. The
being disciplined by procedure is coordinated with the disciplinary policy will be
management or ostracized existing grievance procedure in the communicated to all
2.3.9 by their fellow workers. union contract.See also 2.2.6. Medium employees. Landry 6/30/03
Communication among the
Operators as a group is
probably less than optimal
because of the shift structure
being used at the plant.
Also,it was commented that
communications at shift
change in the recent past
have been brief,with only See 2.2.7. Also,the shift
limited exchange of change procedure will be
information regarding the reviewed and updated
2.3.10 status of plant operations. See 2.3.1 and 2.2.7 High accordingly. Landry 6/30/03
provide the GCRW Plant Manager The Plant Manager,EHS
Plant managers receive no (and other key managers,as Manager and Operations
formal training on appropriate)with the skills Superintendent will attend a
community relations and necessary for effective formal training class on
public outreach to help with communication on environmental communicating environmental
the communication of safety and sa&ty issues with outside and safety issues with the
2.3.11 and environmental issues. parties,including the public. Medium public. Jakonezuk 6/30/03
cipa on in the satety
program has not been fully
embraced by workers,so the
potential from employee
involvement is not being
2.3.12 fully realized. See 2.3.1 High See 2.2.6 and 2.3.1. Landry/Jakonczuk 3/31103
Manager will meet with all
employees to discuss current
Workers are not always safety issues that they might
involved in developing and have. Going forward,the
reviewing safety rules that safety suggestion boxes will
affect their work,especially allow employees the
with respect to personal opportunity to raise safety
protective equipment, issues anonymously. See
2.3.13 clothing,and work permits. See 2.3.1 and 2.3.21 High 2.3.3. Landry/Jakonczuk 3/31/03
some workers perceive that
the safety and health rules
may be too extensive or
prohibitive for the real risks
2.3.14 involved. See 2.3.1 and 2.3.21 See 2.3.13. Landry/Jakonczuk 3/31/03
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There is no performance Consider developing an incentive-
evaluation process for based system for providing hourly
hourly workers that could be workers with rewards for positive
used to require and contributions to safety(see Finding
recognize good safety #2.2.6).For each salaried
performance.Personal employee,ensure that the
performance appraisals and evaluation of safety performance
associated safety (including a session to provide See 2.2.6. Performance
evaluations for salaried feedback to the employee)is evaluations will be performed
people are sometimes conducted on the anniversary date annually for all salaried
delayed beyond the to provide feedback on safety employees and will include a
2.3.1 S anniversary date. issues in a timely manner. Low section on safety. Landry 4/30/03
Conduct a training effectiveness
review of the regulatory Health and
Safety training courses using a
team of workers and managers,and
consider alternative approaches for
providing this training,including"
training"options(provided by a
third party or through the Company
intranet).Using e-training has the
potential of increasing interest
The regulatory safety and level.It would allow individuals to
health training program is schedule training and to proceed
not revised and upgraded on with the training at their own pace.
a routine basis to ensure it It also offers potential cost savings.
maintains participants' (Note.This method may not be All training programs will be
interest.The training is suitable for all training courses, reviewed for effectiveness and
perceived by some to be especially if site-specific or efficiency. Computer based
boring,repetitive,and time- Company-specific requirements training programs will be
consuming.As such the apply.Also,it does not allow for considered for those topics that
training may not be very employees to ask questions directly do not require direct interface
2.3.1b effective. to an instructor) Low with an instructor. Jakonczuk 6/30/03
General Chemical will develop
a formal training program.for
The need for cross-training GCRW management should operators to ensure cross-
Operators in the procedures develop a plan for Operator cross- training. A policy will be
for operating other areas of training and review the plan with developed that will require two
the plant has been the union during the next round of individuals qualified as Lead
recognized by workers and contract negotiations.As soon as a Operators,two individuals
management,but there has mutually acceptable plan has been qualified as"A"Operators and
been no commitment to developed,it should be two individuals qualified as
implement such a cross- implemented within the Operations "B"Operators on shift at all
2.3.17 training program. Department. Medium times. Landry 12/31/03
GCRW should consider
establishing relationships with
other facilities within General
Chemical and/or with companies in
the local area that would allow General Chemical will develop
GCRW plant workers to visit other a program that allows hourly
plants to gain a perspective of how employees to spend time at
others conduct operations and other General Chemical
Workers appear to have a maintenance.This maybe offered facilities,other local facilities
parochial view of operating as a rotation(e.g.,one person per or third-party workshops to
and maintenance practices. month)or as an incentive program learn best management
They have very limited based on individual contributions practices. Employees will be
exposure to operating and to the safety program.As workers selected based on the results of
maintenance practices at identify best practices at other performance evaluations,
other similar facilities facilities,the best practices could participation in safety
within General Chemical be offered for consideration at programs or other similar
2.3.18 and/or within the local area. GCRW. Lowcriteria. Landry 12/31/03
12 of 14
General Chemical-Richmond Works Safety Evaluation Action Item Plan
Update:January 23,2003
All employees will have job
descriptions that include a
section on safety or all
GCRW job descriptions do employee's safety requirements
not explicitly address safety will be explicitly addressed the
2.3.19 Irrquirerntrus. See 2.3.1 High facility's ERS policy. Landry 4/30/03
internalized by the entire
work force.There appears
to be a limited
understanding of the risks
involved,and managers
indicated that personal
protective equipment is not
always worn by workers,as
2.3.20 required. See 2.3.1 and 2.3.21 High See 2.3.1. Landry/Jakonczuk 3/31/03
Conduct a round of safety meetings
at GCRW specifically to address
Worker's concerns about workers'concerns with Personal
wearing eye goggles have Protective Equipment(PPE)such
not been adequately as goggles and clothing.Following
addressed.Workers argue these meetings,revise the PPE
that wearing eye goggles policy,as necessary,to address
could introduce health and legitimate concerns,and develop
safety risks under certain consensus among workers that the
2.3.21 circumstances. policy will be adhered to. High See 2.3.13. Landry/Jakonczuk 3/31/03
tvnuuut 2 111=11M lux 411
supervisors to emphasize the
It appears that some importance of strict adherence to
supervisors may take risks safety and health policies, The Plant Manager and EHS
to get the job done,and risk-procedures,rules and instructions. Manager will meet with all
taking behaviors maybe Supervisors'ability to comply with supervisors to discuss their
permitted or overlooked by this requirement should be rales with respect to safety
some levels of management. included in the supervisors'job leadership. Job descriptions
Some workers indicated descriptions and as a safety will be enhanced with respect
they may be willing to take performance objective in the to safety. Performance
some risks and break safety annual performance reviews.Also evaluations will include a
2.3.22 rales to rescue a man down. sot 2.3 24 High section on safety. Landry'Jakonczuk 4/30/03
The existing shift structure The shift change policy will be
may result in Operators' GCRW managers and supervisors enhanced and include a more
taking undue risks because should review the current policy detailed process during shift
of an unwillingness to requirements for shift change to change. The shift change
request help when it is verify the policies provide adequate checklist will be enhanced.
needed The short duration coverage for the likely risks, General Chemical will
of shift changes may also especially when the plant is going establish minimum staffing
present significant risk in through a startup.Also see 2.2.7 requirements for cold startup,
2.3.23 some situations. and 2.3.17. Medium warm startup and hot startup. Landy 6/30/03
Use the Health and Safety
Committee or a similar forum to
conduct a review of the applicable
safety rules and identify why
workers may perceive they are not
Some workers and practical.For safety rules that are
supervisors consider the deemed to be overly restrictive,
safety rules may not be review the rules and the associated
practical for the"real"risks training to determine if there are
at this plant.They consider ways to help workers comply with
there maybe too many the rule requirements,and
rules,and some rules are minimize the time needed to
2.3.24 difficult to follow, implement the rules. Low See 2.3.13. Landry/Jakonczuk 3/31/03
13 of 14
General Chemical-Richmond Works Safety Evaluation Action Item Plan
Update:January 23,2003
i
At times,there may not be
an adequate number of
Operators at the plant to
work safely.Some examples
of times and work activities
that could introduce risk GCRW plant management should
with insufficient people are: ensure that all open Operator Open positions will always be
(1)during upset conditions; positions are filled as quickly as filled as quickly as possible.
(2)during plant start-up; possible with qualified individuals General Chemical will
and(3)when the Operations in order to avoid experiencing establish minimum staffing
Department has unfilled undue risks because of staff requirements for cold startup,
2.3.25 positions. shortages.Also see 2.3.23 Low warm startup and hot startup. Landry 6/30/03
plant may restrict peoples'
ability to work safely.(This
issue applies more to the
limited expenditures in the General Chemical is in the
past on preventive GCRW is implementing process of developing and
maintenance rather than to improvements to the mechanical implementing an improved
human factors issues integrity program that should Mechanical Integrity program
involved in equipment address the underlying issues that will address the ability of
2.3.26', operation.) associated with this finding. High workers to work safely. Landry 12/31103
Consider implementing a"near-
miss campaign"that focuses
attention on identifying near misses
over a limited period of time.The
campaign could include initial
orientation for workers to help
them identify near misses,a
competitive element(e.g,reporting
by groups,shifts,facility
demographics,etc.),and a rewards
component.After the campaign,
analysis of the near misses could b
used to highlight how the near
misses helped to eliminate risks in A near miss reporting program
the work place.The intent of the will be developed and added to
Workers are not trained to campaign would be to raise the Safety Manual and will
identify and report near awareness of near misses,and help include incentive for reporting
misses,and there is a lack of to increase the motivation of all near misses. Training will be
awareness of what a near workers to report near misses. conducted. An analysis of near
miss is.There are no Consider a follow-up prograrn that misses will be included in the
incentives for reporting near provides incentives for reporting monthly safety council
2.3.27 misses.(See also 2.1.10) near misses on a routine basis. High meetings. Also see 2.2.6. Landry/Jakonczuk 3/31/03
Here t r
many of the workers that promoting a moratorium on near Manager will meet with all
accident investigations are misses,making it clear to workers employees to discuss the
used to identify who is to that there will be no retribution or purpose of accident
blame,rather than to discipline for workers who report investigations and the
address the underlying root near misses.AIso see 2.3.1 and utilization of discipline where
2.3.28 causes. 1 2.3.27 Medium appropriate. Landry/Jakonczuk 3/31/03
supervisors and managers GCRW management should
are concerned over job communicate routine updates to all
security.The recent employees on the financial status
bankruptcy announcement of the Company and the likely
by General Chemical could outcome as it pertains to GCRW. The quarterly meetings
have an adverse impact on These communications should mentioned in 2.3.1 will also be
employee morale and continue regularly until the General used to update employees on
motivation for working Chemical bankruptcy proceedings the status of the Chapter 11
2.3.29 safely. are resolved. High filing. Landry 3/31/03
14 of 14
Readers Forum
The Times
4301 Lakeside Drive
Richmond, CA 94806
The Times published an article on 1/16/03 discussing a Safety Evaluation Report of
General Chemical's Richmond facility. I would like to continue the public dialog started
on this important subject with a few additional facts.
The article highlighted historical issues going back to the 1990's, as is expected.
However, the report also stated that significant positive physical and philosophical
changes have occurred more recently. It cited examples of corporate commitment to
safety including several risk reduction projects, installation of a new emergency scrubber
system and significant enhancements to our mechanical integrity program. In addition,
we will begin construction shortly on a cogeneration facility that will provide our
electricity requirements and improve both efficiency and reliability.
This voluntary evaluation, funded by General Chemical, also identified opportunities for
improvements that we converted into an action plan. 20% of these suggestions have
already been implemented. We will complete another 70%by mid year, and all but the
long-lead equipment related items by year-end.
We look forward to continuing this public dialog on our progress and hope it
demonstrates our commitment to be a responsible member of the local business
community and help fuel the economic engine of the City of Richmond.
Sincerely Yours,
Larry P. Landry
Plant Manager—General Chemicals Richmond Works
510-232-7193 x 226
Letters to the Editor
The San Francisco Chronicle
901 Mission St.
San Francisco, CA 94103
The Chronicle published an article on 1/15/03 discussing a Safety Evaluation Report of
General Chemical's Richmond facility. I would like to continue the public dialog started
on this important subject with a few additional facts.
The article highlighted historical issues going back to the 1990's, as is expected.
However, the report also stated that significant positive physical and philosophical
changes have occurred more recently. It cited examples of corporate commitment to
safety including several risk reduction projects, installation of a new emergency scrubber
system and significant enhancements to our mechanical integrity program. In addition,
we will begin construction shortly on a cogeneration facility that will provide our
electricity requirements and improve both efficiency and reliability.
This voluntary evaluation, funded by General Chemical, also identified opportunities for
improvements that we converted into an action plan. 20% of these suggestions have
already been implemented. We will complete another 70%by mid year, and all but the
long-lead equipment related items by year-end.
We look forward to continuing this public dialog on our progress and hope it
demonstrates our commitment to be a responsible member of the local business
community and help fuel the economic engine of the City of Richmond.
Sincerely Yours,
Larry P. Landry
Plant Manager—General Chemicals Richmond Works
510-232-7193 x 225
;2
Letters to the Editor
East Bay Business Times
6160 Stoneridge Mall Road
Suite 300
Pleasanton, CA 94588
The San Francisco Chronicle and The Contra Costa County Times published articles on
1115&16103 discussing a Safety Evaluation Report of General Chemical's Richmond
facility. I would like to continue the public dialog started on this important subject with a
few additional facts.
The articles highlighted historical issues going back to the 1990's, as is expected.
However, the report also stated that significant positive physical and philosophical
changes have occurred more recently. It cited examples of corporate commitment to
safety including several risk reduction projects, installation of a new emergency scrubber
system and significant enhancements to our mechanical integrity program. In addition,
we will begin construction shortly on a cogeneration facility that will provide our
electricity requirements and improve both efficiency and reliability.
This voluntary evaluation, funded by General Chemical, also identified opportunities for
improvements that we converted into an action plan. 20% of these suggestions have
already been implemented. We will complete another 70%by mid year, and all but the
long-lead equipment related items by year-end.
We look forward to continuing this public dialog on our progress and hope it
demonstrates our commitment to be a responsible member of the local business
community and help fuel the economic engine of the City of Richmond.
Sincerely Yours,
Larry P. Landry
Plant Manager—General Chemicals Richmond Works
510-232-7193 x 226
— General Richmond Works
Chemical525 Castro Street, Richmond, CA 94801
Tel. (510) 232-7193
WORKING WITH OUR COMMUNITY
CAS'` Newsletter
No. l -December 2001
Welcome to Our First Issue
his newsletter shares information about General Chemical Richmond Works
with those who live and work near the plant. It supplements the work of our
Community Advisory Panel (CAP), which has met quarterly since 1998 to
promote a dialog between the plant and the community. The CAP contains several
members of the community and company employees.
Although we consistently communicate news about events at our plant to CAP
members, we have begun this newsletter to ensure important information about
what we are doing reaches as many people in the community as possible. We will
be issuing a newsletter whenever we have important news to share. This issue
gives you an overview of what we do and recent steps we have taken to make our
operation safer.
s Members of the CAIS
(1 to r):Silvana Mosca-Carreon,
Jeff Jakonczuk, Marina Gottschalk,
Martha Watson, Louise Perryman,
Mary Harris, Henry Clark, Lillie
Hagans and non Perez.
Not shown:Raymond Lambert,
Lt.Johan Simon and Rod Satre.
What We Do
The plant is an important recycling facility. It was built in 1944 to reclaim used or
it spent" sulfuric acid from what is now the Chevron Refinery. In essence, we remove
impurities from waste acid sent to us by the refinery and return a "fresh" product for
use in making gasoline. Our process keeps thousands of tons of spent sulfuric acid
out of hazardous waste facilities each year.
About one-third of the sulfuric acid we make is used in non-refining applications to
produce many everyday products. For instance, our sulfuric acid is essential to the
manufacture of the semiconductor chips found in computers and other electronic
devices, car batteries, fertilizers, detergents, drinking water and many foods and
beverages, such as wine and beer.
,rhemical Richmond Works
WORKING WITH OUR CONMUNITY
What's New at the Plant?
Emergency Scrubber. We took a big step in December by adding a significant
precautionary measure. This involved installing a new emergency scrubber that
reduces emissions during many types of upsets in our process. This scrubber will
help us in reaching our ultimate goal: eliminating incidents that impact the
community and the environment.
Third-Party Safety Evaluation. In October, an outside consultant we hired
completed an evaluation of our "safety culture, management systems and human
factors." Initial results were very positive. In the next several months, we will
implement many of the recommendations made by the consultant. This evaluation
was done in cooperation with the City of Richmond and Contra Costa County
Health Services Department after two incidents occurred at the plant in 2001. Our
goal is to go beyond regulatory requirements and foster a mindset among our
employees that supports our overriding vision — zero incidents and no community
impact! The consultants will present the final report to the County Board of
Supervisors and the Richmond City Council on January 14, 2003.
Upcoming Events
If you want to participate in any of the following events, please contact Marina
Gottschalk with Dynamic Networking at (925) 229-8147.
Quarterly CAP Meeting December 18, 2002
Third-Party Evaluation Report January 14, 2003
Quarterly CAP Meeting March 19, 2003
Quarterly CAP Meeting June 18, 2003
Community Plant Tour and Q&A Session Summer 2003
Feedback
Your feedback is critical to the success of this newsletter. To learn more about any
of the items mentioned above or if there are other topics you want to have us
discuss, please contact Jeff Jakonczuk, Environmental, Health and Safety Manager
at (510) 237-3869.
Genera/ Chemical
Richmond Warks
525 Castro Street
Richmond, CA 94801