Ethanol Risk Reduction: Part II, Public Safety

June 3, 2010 |

Ethanol production and transport presents unique safety risks.  Many plants and the public are not prepared for these risks.  Ashly Insco and Evan Nyer of ARCADIS, in a three part series, will provide an overview of the safety issues with the Ethanol and alternative fuel industry.  The series will include Plant Safety, Public Safety and Transportation Safety.  These risks should be addressed during the facility planning process and not after an incident has occurred.  If you do not understand the Risks associated with the safe production and transport of your alternative fuel, then you do not understand the entire financial risks of your business plan.

As always, be sure to contact State and Local authorities as they may have additional safety requirements not addressed in these articles. Part I of the Series, on Plant Safety, is here.

By Evan K. Nyer and Ashly Insco, ARCADIS

Public Safety should be an integral part of the facility design and operation process-which includes public safety in the distribution of the product.  Transportation safety will be covered in the last of the series.  The focus of this article is public safety as it relates to the plant operation.

The Clean Air Act 112(r) program (Risk Management Plan aka RMP) is both a statutory and regulatory program.  It states owners and operators of stationary sources producing, processing and storing extremely hazardous substances have a general duty to identify hazards associated with an accidental release, design and maintain a safe facility, and minimize consequences of accidental releases that occur. The RMP includes an executive summary, registration information, off-site consequence analysis, five-year accident history, prevention program and emergency response program. If your facility produces and or stores these hazardous substances in a quantity that removes your facility from regulation you should still establish a robust RMP.

A memorandum from EPA to State Regulatory Agencies dated April 2, 2010, states “Effective immediately, EPA staff conducting CAA section 112(r) on-site compliance evaluations should offer employees and employee representatives the opportunity to participate in any such evaluations.”

When EPA shows up you want employees to have already been involved in the risk planning process so they can answer questions and provide accurate information. This pro-active approach leads to better coorperation between employees and employer and that leads to a safer operation.  Employees must be empowered to report potential risks to employers. Employers should establish an effective corrective action process to adddress risks identified by employees. Your employees are your best asset in promoting the safety culture exhibited by the plant to the public. And if an incident should occur, community support is critical to re-establishing operations.

Do not wait until an incident has occurred to develop your communication plan-develop a clear plan based on the different incident sceanarios identified in developing the RMP.

Basic items to include in a communication plan are: one point of contact for all communications (ensure 24 hour access to person), standard format for delivery of all verbal and written communication, procedure for legal review of information to be communicated (must be timely), and procedure on how and when additional communications will be made to public.

Include local fire departments and emergency care facilities in your risk management and communications plans.  Invite local fire departments to tour facility at least annually to account for facility changes that could impact emergency response.

Conduct mock spill response drill annually with local fire department.  Document drill results and where opportunities for improvement are identified document the changes in the Spill Response Plan and re-communicate the changes to all parties (employees, spill responders and fire department).

Last, but definitely not least, site security is of utmost importance to Public Safety at facilities producing large quantities of hazardous substances.  The plant and the grounds surrounding the plant should be secured with a monitored access system.  Your security plan should include details on the handling of work place violence, threats of all types (bomb, sabotage, etc.).  Again, practice makes better, so practice security breach scenarios and determine if your system works and if not make it a priority and fix it.  A majority of ethanol plants are located in rural Mid-Western agricultural communities—remember violence happens everywhere.

The series concludes Friday with an examination of Transport Safety.

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