Emergency Response Training

GENG Ltd. can provide emergency response training for all plant personnel
based on the requirements of OSHA. Emergency response training should be
provided as part of a comprehensive effort to develop a process safety
management plan for the site. Such a plan is required by OSHA regulations.
The table of contents for the applicable regulations is provided below with some
explanation for specific elements.

1910.38 - Emergency Action Plans.

1910.38(a)
Application. An employer must have an emergency action plan
whenever an OSHA standard in this part requires one. The requirements
in this section apply to each such emergency action plan.

1910.38(b)

Written and oral emergency action plans. An emergency action plan

must be in writing, kept in the workplace, and available to employees for
review. However, an employer with 10 or fewer employees may
communicate the plan orally to employees.

1910.119 - Process safety management of highly hazardous

chemicals.

1910.119 App A - List of Highly Hazardous Chemicals, Toxics and

Reactives (Mandatory).

1910.119 App B - Block Flow Diagram and Simplified Process Flow

Diagram (Nonmandatory).

1910.119 App C - Compliance Guidelines and Recommendations for

Process Safety Management (Nonmandatory).

Introduction to Process Safety Management. The major objective of

process safety management of highly hazardous chemicals is to prevent
 unwanted releases of hazardous chemicals, especially into locations
which could expose employees and others to serious hazards. An
effective process safety management program requires a systematic
approach to evaluating the whole process. Using this approach the
process design, process technology, operational and maintenance
activities and procedures, non-routine activities and procedures,
emergency preparedness plans and procedures, training programs, and
other elements which impact the process are all considered in the
evaluation.

The process safety management standard targets highly hazardous

chemicals that have the potential to cause a catastrophic incident. This
standard as a whole is to aid employers in their efforts to prevent or
mitigate episodic chemical releases that could lead to a catastrophe in
the workplace and possibly to the surrounding community. To control
these types of hazards, employers need to develop the necessary
expertise, experiences, judgment and proactive initiative within their
workforce to properly implement and maintain an effective process safety
management program as envisioned in the OSHA standard. This OSHA
standard is required by the Clean Air Act Amendments as is the
Environmental Protection Agency's Risk Management Plan. Employers,
who merge the two sets of requirements into their process safety
management program, will better assure full compliance with each as
well as enhancing their relationship with the local community.

1910.119 App D - Sources of Further Information (Nonmandatory).

1910.120 - Hazardous waste operations and emergency response.

1910.120 App A - Personal protective equipment test methods.

1910.120 App B - General description and discussion of the levels

of protection and protective gear.

1910.120 App C - Compliance guidelines.

 1. The program will provide the means for identifying and controlling
worksite hazards and the means for monitoring program effectiveness.

Each site safety and health program will need to include the following:
means to anticipate and prepare for emergency situations and;
management and employees should be trying continually to improve the
effectiveness of the program thereby enhancing the protection being
afforded those working on the site.

For the development and implementation of the program to be the most

effective, professional safety and health personnel should be used.
Certified Safety Professionals, Board Certified Industrial Hygienists or
Registered Professional Safety Engineers are good examples of
professional stature for safety and health managers who will administer
the employer's program.

2. Training. The training programs for employees should address: the

safety and health hazards employees should expect to find.

1910.120 App D - References.

1910.120 App E - Training Curriculum Guidelines - (Non-mandatory)

Emergency response training is an essential part of a comprehensive process

safety management (PSM) program. The OSHA regulations pertain mainly to
release of toxic or flammable process material. A plant PSM program needs to
incorporate plant fire emergency response training. The PSM program may
also incorporate the EPA risk management program (RMP) to be in compliance
all areas of government regulation.

Emergency response training is essential for the safety and well being of
employees and people living near the plant. However, it is only a part of a
PSM/RMP program to manage emergencies and provide risk management
capabilities on the site. Process Technical Services has experienced and
professionally trained personnel able to manage the development of a
combined PSM/RMP program with emergency response procedures and
emergency response training for the entire organization.