Management Audit Checklist

Implementation of AFR H&S Manual Procedures

AFR Managers, Environmental Coordinators and Occupational Health & Safety

Coordinators have the responsibility for ensuring that the provisions of this

Alternative Fuels and Raw Materials (AFR) Health and Safety (H&S) Manual are

properly implemented. To assist management, this audit checklist has been

developed to provide basic guidance in the implementation of key areas of the

Manual. This checklist is based upon the Safety and Health Guide for the

Chemical Industry (OSHA 3091), Hazardous Waste Operations and Emergency

Response (OSHA 3114), and Holcim Self -Assessment Audit Protocol for: The

Holcim Occupational Health and Safety Pyramid. It is assumed that managers

are already familiar with the operation of their facility, the general duties of its

personnel, and the basic types of AFR materials handled and processed at the

facility. The focus of this audit checklist is directed toward those sections of the

Manual concerned with identification of chemical hazards, selection and use of

personal protective equipment, workplace and personal monitoring, emergency

procedures, and employee training and record-keeping. The checklist can be

used as an aid to the collection of necessary facility-specific information, and the

development of facility-specific procedures, as appropriate.

ROLES, RESPONSIBILITIES, AND ACCOUNTABILITY

____ Who is in charge? What are the lines of authority under normal operating
conditions? In transition times, such as start-up and shutdown procedures?
In emergencies?

____ Can information be transmitted quickly and easily from: worker to

supervisor? Supervisor to worker?

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____ How is information exchange accomplished during transition periods
(starting and stopping work)?

____ Is operator jargon commonly and completely understood by those affected

by the jargon? Examples: CSS- impregnated sawdust, cribs/storage bins

____ Are warning signals clear? Are audible signals distinguishable and
understood?

____ Has management followed recommended hazard communication

standards? Example: OSHA (29 CFR 1910.1200).

____ Are monitoring records, training records, and material safety data sheets
available?

____ Are standard operating procedures available? Is there a process for

reviewing and updating procedures including communication and training?

____ Does a written emergency plan exist? For what scenarios?

____ What are the job classifications of employees who work at the site? Are all
job titles present on all work shifts? Are there potentially crucial omissions?

____ Is there a means to quickly and accurately account for all persons on site?

____ Who is responsible for training employees? How often is training provided
covering standard operating procedures? Emergency procedures? How is
effectiveness of training evaluated by management?

FACILITY LAYOUT

____ Are workers familiar with the site layout?

____ Have emergency meeting sites been designated?

____ Is site orientation mandatory for visitors? Restrooms? Prohibited activities

and areas? First aid stations?

____ Are there work zone signs indicating chemical hazards, proper PPE, first
aid stations, and emergency contacts?

____ Are work areas well maintained? (Housekeeping issues)

____ Is the facility designed for separation and isolation ? Reactive chemicals?
Explosives? Compressed gases?

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____ Are pumps and compressors appropriate for designated use? Are remotely
controlled switches and shutoff valves available and functioning in case of
emergencies?

____ Has equipment been selected/maintained to minimize vibrations which can

loosen fittings and joints during transfer of flammable vapors or gases?

____ Where hazardous liquids may leak or spill from piping or vessels, what
provisions have been made to prevent their spread to areas where
employees may be exposed to the hazards? Example: special drains for
contaminated liquids, containment ponds, etc.

____ Does the facility have special provisions to control unexpected hazardous
vapor or gas releases within the drain lines? Are there any monitoring or
warning systems?

____ If areas of potential or frequent leaks or spills are enclosed to prevent

environmental contamination or the spread of the chemical, are there
adequate precautions to protect employees?

____ Is storage tank design based upon quantity, temperature, pressure,

reactivity, and corrosiveness of material stored? Does the design include
overpressure equipment and vents related to the interrelationship of the
whole system?

____ Are exhaust stacks and air intakes so located that contaminated air will not
be recirculated within a building or other enclosed area?

____ Is the ventilation system adequate to achieve proper air exchange?

____ Are systems in place for odor control? Example: Thermal catalytic
oxidizers or activated carbon?

____ Are engineering controls examined and maintained or replaced on a

scheduled basis?

CHEMICAL HAZARD IDENTIFICATION

____ Is a copy of the Holcim AFR H&S Manual on file and accessible to all
employees with signs notifying employees of its location?

____ Are Material Safety Data Sheets (MSDSs) on file and accessible to all
employees with signs notifying employees of their location?

____ Have control procedures been instituted for hazardous materials, where
appropriate?

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____ When AFR materials are received, are the specific chemical constituents
determined to assess the specific hazards they may represent?

____ Are AFR materials (i.e., solvents, sludges, CSS) properly marked, stored,
covered, and handled?

____ Are incompatible AFR materials stored and handled separately?

____ Are flammable liquids and hazardous materials stored correctly?

____ Have AFR materials that can produce harmful dusts been identified?

____ Have AFR materials that can irritate or damage the skin or eyes been
identified?

____ Have AFR materials that may constitute a fire or explosion hazard been
identified?

____ Do any of the AFR materials constitute a splash hazard?

____ Do the AFR materials release mists, vapors, or gases?

____ Are employees aware of the hazards and potential health effects involved
with the various chemicals they may be exposed to in their work
environment, such as ammonia, pesticides, epoxies, caustics, etc.?

____ Are hazardous substances, blood, and other potentially infectious materials
identified, that may cause harm by inhalation, ingestion, and skin absorption
or contact?

____ Are all containers such as vats, storage tanks, etc., labeled as to their
contents, e.g., "CAUSTICS"?

____ Are employees prohibited from eating, drinking, or smoking in areas where
hazardous chemicals are present?

PERSONAL PROTECTIVE EQUIPMENT

____ Is a copy of the Holcim AFR H&S Manual, containing guidance on selection
of personal protective equipment, on file and accessible to all employees
with signs notifying employees of its location?

____ Are occupational exposure guidance values (Permissible Exposure Limits,

Threshold Limit Values, etc.) for hazardous chemical constituents of AFR
materials on file and accessible to employees?

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____ Are all employees familiar with the Threshold Limit Values or Permissible
Exposure Limits of airborne contaminants and physical agents used in the
workplace?

____ Are all employees familiar with the Immediately Dangerous to Life or Health
(IDLH) values for AFR materials they may come in contact with?

____ Are employees required to use personal protective clothing and equipment
when handling chemicals (gloves, eye protection, respirators, etc.)?

____ Is personal protective equipment provided, used, and maintained wherever

required?

____ Are respirators regularly inspected, cleaned, and sanitized?

____ Are chemical-resistant gloves available?

____ Are cut-resistant gloves available?

____ Are leather work gloves available?

____ Are chemical-resistant, steel-toed steel shank boots available?

____ Are steel-toed, steel shank safety shoes available? Are Kevlar-toed, safety
shoes available for non-spark zones?

____ Is chemical-resistant body protection (Tyvek, Nomex) available?

____ Are safety glasses or goggles available?

____ Are face shields available?

____ Are dust masks available?

____ Are air purifying respirators (HEPA, organic vapor, acid gas, etc.)
available?

____ Are powered air purifying respirators (PAPR) available?

____ Is a supplied air system available?

____ Is Self Contained Breathing Apparatus (SCBA) available?

WORKPLACE AND PERSONAL MONITORING

____ Is the work area's ventilation system appropriate for the work being
performed?

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____ Has the facility been inspected by an industrial hygienist or environmental
health specialist to evaluate areas of potential employee exposure to AFR
chemical constituents?

____ Have air monitoring samples (short-term grab samples, long-term

monitoring) been taken to determine potential exposure concentrations of
chemicals in the workplace?

____ Is employee exposure to chemicals in the workplace kept within acceptable

levels (Permissible Exposure Limits, Threshold Limit Values, etc.)?

____ Have personal air monitoring samples been taken to estimate individual
exposure to chemicals in the workplace?

____ If internal combustion engines are used in enclosed areas, is carbon

monoxide kept within acceptable levels?

____ Are enclosed storage or work areas (silos, bins, work areas with open vats)
routinely monitored to ensure that concentrations of hazardous chemicals
are kept at acceptable levels?

____ Are confined spaces monitored prior to entry to assess the need for
personal protective measures?

____ Are employees screened before assignment to areas of potentially high

chemical concentrations to determine if their health condition might make
them more susceptible to having an adverse reaction?

____ Do employees complain about dizziness, headaches, nausea, irritation, or

other factors of discomfort when working with AFR materials?

____ Is there a dermatitis problem? Do employees complain about dryness,

irritation, or sensitization of the skin?

____ For employees who routinely handle AFR materials and who may have
long-term contact with hazardous substances, is medical or biological
monitoring available to assess their health status?

____ Are employee medical records and records of employee exposure to

hazardous substances or harmful physical agents up-to-date and in
compliance with applicable company standards?

EMERGENCY PROCEDURES

____ Is there an emergency plan? Natural disaster senario? Procedure to

update?

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____ Is the emergency plan available to all key personnel up and down the
chain of command including employee representatives and the switchboard
operator?

____ Is a copy of the Holcim AFR H&S Manual on file and accessible to
emergency response personnel? Holcim OH&S Handbook or local
adaptation thereof?

____ Are Material Safety Data Sheets (MSDSs) on file and accessible to
emergency response personnel?

____ Have emergency response personnel been designated and trained in

specific emergency response procedures?

____ Is emergency contact information (fire, medical, police) available to

emergency response personnel?

____ Has the facilities' emergency response plan been coordinated with
community emergency and rescue agencies? Local governments? Mutual
aid industries? Utility companies?

____ Are employees instructed in proper first-aid and other emergency

procedures?

____ Are first aid supplies properly stocked and accessible?

____ Have standard operating procedures been established and are they being
followed when cleaning up chemical spills?

____ Where corrosive or caustic liquids are frequently handled in open

containers or drawn from storage vessels or pipe lines, are adequate
means readily available for neutralizing or disposing of spills or overflows
properly and safely?

____ Are eye wash fountains and safety showers provided in areas where
corrosive chemicals are handled?

____ Is containment equipment (booms, adsorbent materials) stored in a readily

accessible location for use by emergency response personnel?

____ Are all spilled hazardous materials or liquids, including blood and other
potentially infectious materials, cleaned up immediately and according to
proper procedures?

____ Is AFR-specific personal protective equipment (respirators, Tyvek suits or

other body protection, gloves, boots) intended for emergency use stored in
a convenient, clean, and sanitary location?

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____ Are respirators intended for emergency use adequate for the various
situations in which they may be needed?

____ Where needed for emergency use, is Self Contained Breathing Apparatus
(SCBA) available?

____ Is Level A Suit protection available (when appropriate)?

____ Is Level B Suit protection available (when appropriate)?

____ Is Level C Suit protection available (when appropriate)?

EMPLOYEE TRAINING AND RECORDKEEPING

____ Are employees trained in understanding hazard communications?

____ Are employees familiar with the location and use of the AFR H&S Manual?
Holcim OH&S Handbook or local adaptation thereof?

____ Are employees aware of the location of MSDSs and trained in the proper
use of these and other relevant reference materials that provide information
concerning the hazards, safe handling, and safe storage of AFR materials?

____ Are employees trained in "Lock out, Tag out" procedures? Example:
working on moving or energized equipment

____ Is hazardous work training and a permit system in place? Examples:

excavation, enclosed spaces, work at heights, hot work, energized systems,
etc.

____ Are employees trained in the safe handling practices of hazardous

chemicals such as acids, caustics, solvents, etc.?

____ Are employees trained in the relevant exposure limits for the hazardous
substances that may constitute AFR materials?

____ Are employees trained in the proper selection, use, and care of personal
protective equipment?

____ Are employees trained to recognize the signs and symptoms associated
with exposure to hazardous chemicals?

____ Are employees trained in the proper use and care of workplace and
personal monitoring devices?

____ Are employees trained in the proper emergency response actions

applicable to their duties?

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____ Have emergency response team personnel received specialized training in
emergency response actions including knowledge of appropriate
containment procedures, use of protective equipment, cleanup and disposal
methods, and post-cleanup clearance procedures?

____ Are signs warning of prohibited actions (e.g., no smoking, no open flames)
in place where necessary?

____ Are caution labels and hazard signs properly posted in appropriate
locations to warn of hazardous substances (e.g. pesticides), biohazards
(e.g. bloodborne pathogens), and hazardous conditions (e.g., fire danger)?

____ Are employees provided training in the meaning of various hazard warning
signs and labels and the appropriate actions to take?

____ Are all occupational injury or illnesses, except minor injuries requiring only
first aid, being recorded as required?

____ Are employee training records maintained on file and made available for
review by employees?

____ Have arrangements been made to maintain required records for the
applicable legal period of time for each specific type of record?

____ Are employees aware of the proper procedures for submitting comments
and proposing changes to the AFR H&S Manual? Holcim OH&S Handbook
or local adaptation thereof? Are employees encouraged in this activity?