POLICIES AND PROCEDURES MANUAL
The procedures manual, a collection of individual task procedures, forms the basic guiding document for the consistent completion of core responsibilities and is absolutely critical from a propane safety perspective. The scope of written policies includes language to cover legal issues that may arise due to the nature of the business, employee health and welfare (especially in hazardous operational conditions), and/or ethical concerns that may put the organization or the employee in a position of conflict.
- A critical element of every company
- Must be written and communicated during onboarding process and reviewed regularly
- A baseline of +/- 30 is a nice starting place
- Distracted driving
- Employee training requirements
- Out of gas delivery
- Evacuating containers
- General bobtail loading and unloading procedures
OSHA COMPLIANCE
OSHA Emergency Action Plan
- Required by OSHA 29 CFR 1910.38 at all bulk storage facilities and/or offices
- Must be communicated to all employees verbally
- If greater than 10 employees, must be written
OSHA HAZCOM Program
- Required by OSHA 29 CFR 1910.1200
- Top 5 cited violations annually by OSHA
- Fines average $5K?$10K
- Program includes 4 main components
- Hazardous Chemical List
- Safety Data Sheets (SDS)
- Labeling Requirements
- Employee Training
TRAINING
- Classroom Training
- CETP, OSHA, DOT
- Cathodic Protection
- Customized Field Training
- Hands-on
- Skills evaluation
- Driver ride-alongs
BULK PLANTS
Operations and Maintenance Manual
- Required by NFPA 58 Chapter 14 for LP bulk plant facilities
- Must contain written operating procedures for activities in LP bulk plant
- Must contain written maintenance procedures, manuals, and records for the facility
- Records must be maintained for the life of the equipment/facility
Fire Safety Analysis
- NFPA 58 2001 Edition requires all new or existing LP bulk storage plants with an aggregate capacity of 4,000 gallons or more to have an FSA completed and submitted to Fire Service
HAZMAT Security Plan
- 49 CFR – DOT requirement for LP bulk plants and shipments of bulk quantities of propane
- Written security plan training required and must include:
- Company Security Objectives
- Company Security Structure
- Personnel Security
- Unauthorized Access
- Enroute Security