Chapter 3. Industrial Hygiene Industry and society are continuing to focus on reducing personnel and environmental damage resulting from accidents. Many of the results in this area are due to civic concern and ethics, sometimes manifested in laws and regulations. In this chapter we describe the relationship between laws and regulations as an introduction to industrial hygiene. Industrial hygiene is a science devoted to the identification, evaluation, and control of occupational conditions that cause sickness and injury. Industrial hygienists are also responsible for selecting and using instrumentation to monitor the workplace during the identification and control phases of industrial hygiene projects. Typical projects involving industrial hygiene are monitoring toxic airborne vapor concentrations, reducing toxic airborne vapors through the use of ventilation, selecting proper personal protective equipment to prevent worker exposure, developing procedures for the handling of hazardous materials, and monitoring and reducing noise, heat, radiation, and other physical factors to ensure that workers are not exposed to harmful levels. The four phases in any industrial hygiene project are anticipation, identification, evaluation, and control: + Anticipation: expectation of the presence of workplace hazards and worker exposures + Identification: determination of the presence of workplace exposures + Evaluation: determination of the magnitude of the exposure + Control: application of appropriate technology to reduce workplace exposures to acceptable levels In chemical plants and laboratories the industrial hygienist works closely with safety professionals as an integral part of a safety and loss prevention program. After identifying and evaluating the hazards, the industrial hygienist makes recommendations relevant to control techniques. The industrial hygienist, safety professionals, and plant operations personnel work together to ensure that the control measures are applied and maintained. It has been clearly demonstrated that toxic chemicals can be handled safely when principles of industrial hygiene are appropriately applied. 3-1. Government Regulations Laws and Regulations Laws and regulations are major tools for protecting people and the environment. Congress is responsible for passing laws that govern the United States. To put these laws into effect, Congress authorizes certain government organizations, including the Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA), and the Department of Homeland Security (DHS) to create and enforce regulations. Creating a Law A law is created with a three-step process: Step 1. A member of Congress proposes a bill. A bill is a document that, if approved, becomes a law. Step 2. If both houses of Congress approve the bill, it is sent to the president, who has the optionto either approve it or veto it. If approved, it becomes a law that is called an act. Step 3. The complete text of the law is published in the United States Code (USC).! The code is the official record of all federal laws. Creating a Regulation After the law is official, how is it put into practice? Laws often do not include the details for compliance. For example, the USC requires the appropriate respirator protection, but it does not specify the detailed types or limitations of respirators. To make the laws work on a day-to-day level, Congress authorizes governmental organizations, including the EPA, OSHA, and DHS, to create regulations and/or standards. Regulations set specific rules about what is legal and what is not legal. For example, a regulation relevant to the Clean Air Act will specify levels of specific toxic chemicals that are safe, quantities of the toxic chemicals that are legally emitted into the air, and what penalties are given if the legal limits are exceeded. After the regulation is in effect, the EPA has the responsibility (1) to help citizens comply with the law and (2) to enforce the regulation. The process for creating a regulation and/or standard has two steps: Step 1. The authorized organization or agency decides when a regulation is needed. The organization then researches, develops, and proposes a regulation. The proposal is listed in the Federal Register (FR) so that the public can evaluate it and send comments to the organization. These comments are used to revise the regulation. Step 2. After a regulation is rewritten, it is posted in the Federal Register as a final rule, and it is simultaneously codified by publishing it in the Code of Federal Regulations (CFR). In 1970 the U.S. Congress enacted a health and safety law that continues to have a significant impact on the practices of industrial hygiene in the chemical industry: the Occupational Safety and Health Act of 1970 (OSHAct). To appreciate the significance of the OSHAct, it is helpful to review regulations and practices? before 1970. Before 1936 regulations concerning occupational health were poorly administered by state and local governmental agencies. During this era, staffs and funds were too small to carry out effective programs. In 1936 the federal government enacted the Walsh-Healy Act to establish federal safety and health standards for activities relating to federal contracts. This 1936 act also initiated significant research related to the cause, recognition, and control of occupational disease. The concepts promulgated by the Walsh-Healy Act, although not adequate by today’s standards, were the forerunners of our current occupational health and safety regulations. Between 1936 and 1970 a number of states enacted their own safety and health regulations. Although some progress was made, these regulations were never sufficiently supported to carry out a satisfactory program. This produced relatively inconsistent and ineffective results. The OSHAct of 1970 was developed to solve these problems and to give a nationally consistent program with the funding necessary to manage it effectively. This act defined clear procedures for establishing regulations, conducting investigations for compliance, and developing and maintaining safety and health records. As a result of the OSHAct, sufficient funding was committed to create and support the Occupational Safety and Health Administration (OSHA), which manages and administers the government’ sresponsibilities specified in the OSHAct, and the National Institute for Occupational Safety and Health (NIOSH), which conducts research and technical assis improving the protection and maintenance of workers” health. Examples of NIOSH responsibilities include (1) measuring health effects of exposure in the work environment, (2) developing criteria for handling toxic materials, (3) establishing safe levels of exposure, and (4) training professionals for administering the programs of the act. NIOSH develops data and information regarding hazards, and OSHA uses these data to promulgate standards. Some laws and regulations particularly relevant to the chemical industry are shown in Table 3-1. As illustrated in this table, the distinction between laws (USC) and regulations (CFR) is global versus detail. Table 3-1. A Few Laws from the United States Code (USC) and Regulations from the Code of Federal Regulations (CFR) Number Description 20 USC 651 Occupational Salety and Health Act (1970) 42 USC 7401 Clean Air Act (1970) 33 USC 1251 Clean Water Act (1977) 42 USC 7401 Clean Air Act Amendments (1990) 15 USC 2601 Toxic Substances Control Act II (1992) 42 USC 300f Safe Drinking Water Act Amendment (1995) 40 CFR 280.20 Underground Storage Tank Leak Tests (1988) 40 CFR 370.30 Annual Toxic Release Report, SARA 313 (1989) 29 CER 1910.120 ‘Training, Hazardous Materials Technician, HAZMAT (1989) 29 CFR 1910.1450, Exposure to Hazardous Chemicals in Laboratories (1990) 40 CFR 370.20 Annual Inventory of Hazardous Chemicals. SARA 311 (1991) 29 CER 1910.19 Process Safety Management (1992) 40 CFR 68.65 Risk Management Program (1996) 29 CFR 1910.134 Respirator Program (1998) 42 USC 7401 Chemical Safety Information, Site Security and Fuels Regulatory Act (1999) 49 USC 40101 Transportation and Security Act (2001) 6 USC 101 Homeland Security Act (2002) 42 USC 301 Federal Food, Drug and Cosmetic Act (2002) 42 USC 13201 Energy Policy Act (2005) 29 CFR 1910 Subpart $_ Electrical Standard (2007) 6 CFR27 Chemical Facility Anti-Terrorism Standards (CFATS) (2007) The OSHAct makes employers responsible for providing safe and healthy working conditions for their employees. OSHA is authorized, however, to conduct inspections, and when violations of the safety and health standards are found, they can issue citations and financial penalties. Highlights of OSHA enforcement rights are illustrated in Table 3-2. Table 3-2. Highlights of OSHA’s Right of EnforcementEmployers must admit OSHA compliance officers advance notice. A search warrant may be requi nto their plant sites for safety inspections with no d to show probable cause. OSHAS right of inspection includes safety and health records. Criminal penalties be invoked, s finding conditions of imminent dai + may request plant shutdowns. The implications, interpretations, and applications of the OSHAct will continue to develop as standards are promulgated. Especially within the chemical industry, these standards will continue to create an environment for improving process designs and process conditions relevant to the safety and health of workers and the surrounding communities. Government regulation will continue to be a significant part of the practice of chemical process safety. Since the OSHAct was signed into law, substantial new legislation controlling the workplace and community environment has been enacted. Table 3-3 provides a summary of relevant safety legislation. Table 3-4 summarizes the important parts of the current OSHAct. Table 3-3. Federal Legislation Relevant to Chemical Process Safety*Date Abbreviation Act 1899 RHA River and Harbor Act 1906 FDCA Federal Food, Drug, and Cosmetic Act 1947 FIFRA Federal Insecticide, Fungicide, and Rodenticide Act 1952 DCA Dangerous Cargo Act 1952 FWPCA Federal Water Pollution Control Act 1953 FFA Flammable Fabrics Act 1954 AEA Atomic Energy Act 1956 FWA Fish and Wildlife Act of 1956 1960) FHSA :deral Hazardous Substances Labeling Act 1965 SWDA Solid Waste Disposal Act 1966 MNMSA Metal and Non-Metallic Mine Safety Act 1969 NEPA National Environmental Policy Act 1969 CMHSA Federal Coal Mine Health and Safety Act 1970 CAA Clean Air Act 1970) PPPA Poison Prevention Packaging Act of 1970, 1970 wol Water Quality Improvement Act of 1970 1970 RSA Federal Railroad Safety Act of 1970. 1970 RRA Resource Recor Act of 1970 1970 OSHA Occupational Salety and Health Act 1972 NCA Noise Control Act of 1972 1972 FEPCA Federal Environmental Pollution Control Act 1972 HMTA Hazardous Materials Transportation Act 1972 CPSA Consumer Product Safety Act 1972 MPRSA Marine Protection, Research, and Sanctuary Act of 1972 1972 CWA Clean Water Act 1972 -ZMA, Coastal Zone Management Act 1973 ESA Endangered Species Act of 1973 1974 SDWA Safe Drinking Water Act 1974 TSA Transportation Safety Act of 1974 1974 ESECA, Ener, upply and Environmental Coordination Act1976 1976 1977 1977 1978 1978 1980, 1984 1086, 1986, 1986 1986, 1987 1990, 1990 1990) 1992 1992 1993 1904 1996 1996 1996, 1996, 1996 1999 2001 2002 2005 2007 TSCA RCRA FMSHA. SMCRA UMTCA PTSA CERCLA HSWA AHERA SARA EPCRA TSCA WOA OPA CAAA PPA TSCA-II NEPA HMTAA SDWA FOPA EPCRA FEDCA FIFRA TSA HAS CFATS Toxic Substances Control Act Resource Conservation and Recovery Act Federal Mine Safety and Health Act Surface Mine Control and Reclamation Act Uranium Mill Tailings Control Act Port and Tanker Safety Act Comprehensive Environmental Response, Compensation, and Liabil- ity Act of 1980 (Superfund) Havardous and Solid Waste Amendments Asbestos Hazard Emergency Response Act Superfund Amendments and Reauthorization Act Emergency Planning and Community Right-to-Know Act Toxic Substances Control Act Water Quality Act Oi Pollution Act of 1990 Clean Air Act Amendments Pollution Prevention Act of 1990 Residential Lead-Based Paint Hazard Abatement Act Federal Facility Compliance Act National Environmental Policy Act Havardous Materials Transportation Act Amendments Sale Drinking Water Act Amendment Food Quality Protection Act Emergeney Planning and Community Right-to-Know Act Federal Food, Drug and Cosmetic Act Insecticide, Fungicide, and Rodenticide Act Community Safety Information, Site Security and Fuels Regulatory Act ‘Transportation and Security Act Homeland Security Act Energy Policy Act Chemical Facility Anti-Terrorism Standards 4 Information from the EPA and OSHA web sites: www.epa.gov and www.osha.gov. Table 3-4. Parts of the OSHAct Relevant to Chemical Engineering Practice.Part Title 1910.95 Occupational noise exposure 1910.97 Non-ionizing radiation 1910 Subpart H Hazardous materials 1910,106 Flammable and combustible liquids 1910.110 Storage and handling of liquefied petroleum gases 1910.19 Process safety management of highly hazardous chemicals 1910,120 Hazardous waste operations and emergency response 1910 Subpart 1 Personal protective equipment 190.133 Eye and face protection 1910,134 Respiratory protection 1910,135 Head protection 1910.136 Foot protection 1910138 Hand protection 1910 Subpart L Fire protection 1910 Subpart N Materials handling and storage 1910 Subpart O Machinery and machine guarding 1910 Subpart P Hand and portable tools and other hand equipment 1910 Subpart Welding, cutting and braving, 1910 Subpart S Electrical 1910 Subpart Z Toxic and hazardous substances—this includes regulations for specific chemicals 19101200 Hazard communication 1910.1450 Occupational exposure to hazardous chemicals i tori 4 These are all part of 29 CRF 1910. See wwww.osha.gov for details, OSHA: Process Safety Management On February 24, 1992, OSHA published the final rule “Process Safety Management of Highly Hazardous Chemicals.” This standard is performance oriented; that is, it sets general requirements for the management of hazardous chemicals. Process safety management (PSM) was developed after the Bhopal accident (1984), to prevent similar accidents. It is recognized by industry and the government as an excellent regulation that will reduce the number and magnitude of accidents—if it is understood and practiced as intended. The PSM standard has 14 major sections: employee participation, process safety information, process hazard analysis, operating procedures, training, contractors, pre-startup safety review, mechanical integrity, hot work permits, management of change, incident investigations, emergency planning and response, audits, and trade secrets. A brief description of each section is given in what follows. Employee participation requires active employee participation in all the major elements of PSM. Employers must develop and document a plan of action to specify this participation. Process safety information is compiled and made available to all employees to facilitate the understanding and identification of hazards. This information includes block flow diagrams or process flow diagrams, process chemistry, and process limitations, such as temperatures, pressures, flows, and compositions. Consequences of process deviations are also required, This process safetyinformation is needed before training, process hazards analysis, management of change, and accident investigations. Process hazard analysis (PHA) must be performed by a team of experts, including engineers, chemists, operators, industrial hygienists, and other appropriate and experienced specialists. The PHA needs to include a method that fits the complexity of the process, a hazards and operability (HAZOP) study for a complex process, and for less complex processes a less rigorous process, such as what-if scenarios, checklists, failure mode and effects analysis, or fault trees. Employers must ensure that the recommendations from the PHA are acted on ina timely manner. Every PSM process needs an updated PHA at least every five years after the initial analysis is completed. Operating procedures that facilitate the safe operation of the plant must be documented. These instructions must be clearly written and consistent with the process safety information. They need to cover, at a minimum, initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, startup after normal and emergency shutdowns, operating limits and consequences of deviations, safety and health considerations, hazardous properties of the chemicals, exposure precautions, engineering and administrative controls, quality control specifications for all chemicals, special or unique hazards, and safety control systems and functions. Safe work practices also need to be documented, such as hot work, lockout/tagout, and confined space. These operating procedures are updated frequently, with the frequency being set by the operating personnel. Aneftective training program helps employees understand the hazards associated with the tasks they perform. Maintenance and operations personnel receive initial training and refresher training. Operators need to understand the hazards associated with every task, including emergency shutdowns, startups, and normal operations. Refresher training is given every three years and more often if necessary; the operators decide on the frequency of the refresher training. Contractors are trained to perform their tasks safely to the same extent as employees. Even when selecting contractors, the employees need to consider the contractors’ safety performance in addition to their skills. A pre-startup safety review is a special safety review that is conducted after a modification to the process or operating conditions has been made and before the startup. In this review a team of reviewers ensures that (1) the system is constructed in accordance with the design specifications, (2) the safety, maintenance, operating, and emergency procedures are in place, (3) the appropriate training is completed, and (4) the recommendations from the PHA are implemented or resolved. The mechanical integrity section of the PSM standard ensures that the equipment, piping, relief systems, controls, and alarms are mechanically sound and operational. The requirements include (1) written procedures to maintain functioning systems, (2) training regarding preventive maintenance, (3) periodic inspections and testing based on vendor recommendations, (4) a process to correct deficiencies, and (5) a process to ensure that all equipment and spare parts are suitable. The PSM standard ascertains that a system is in place to prepare and issue hot work permits before conducting hot work activities (welding, grinding, or using spark-producing equipment). The permit requires dates authorized for hot work, the equipment involved in the work, a system to maintain and document certification, identification of openings where sparks may drop, the types and numbers of fire extinguishers, identification of fire watches, an inspection before the work, authorizationsignatures, identification of flammable materials in the area, verification that the surrounding area is not explosive, verification that combustible materials are removed or covered appropriately, identification and closure of open vessels or duets, and verification that welded walls are not flammable. Under the management of change section of the PSM standard employees are required to develop and implement documented procedures to manage changes in the process chemistry, process equipment, and operating procedures. Before a change occurs (except for replacement-in-kind), it must be reviewed to ascertain that it will not affect the safety of the operation. After the change has been made, all the affected employees are trained, and a pre-startup review is conducted. The PSM standard mandates incident investigation. Employers must investigate all incidents that have or could have resulted in a major release or accident within 48 hours of the event. The regulation requires an investigation team composed of people, including operators, who are knowledgeable about the system. Afler the investigation, the employers are required to appropriately use the investigation recommendations. The intent of the PSM element for emergency planning and response is to require employers to respond effectively to the release of highly hazardous chemicals. Although the regulation requires this activity for companies with more than 10 employees, this element should be part of a program for even the smallest organizations that handle hazardous chemicals. Under the audits section of the PSM standard employers are required to certify that they have evaluated their compliance with the standard at least every three years. The recommendations from the audit must be followed. The audit reports need to be retained as long as the process exists. The trade secrets section of the PSM standard ensures that all contractors are given all the information relevant to operating in the plant safely. Some personnel may need to sign secrecy agreements before they receive this information. EPA: Risk Management Plan On June 20, 1996, the EPA published the Risk Management Plan (RMP) as a final rule. This regulation is also a response to the Bhopal accident. It is recognized by industry and the government as an excellent regulation that will reduce the number and magnitude of accidents—if it is understood and practiced as intended. ‘The RMP regulation is aimed at decreasing the number and magnitude of accidental releases of toxic and flammable substances. Although the RMP is similar to the PSM regulation in many respects, the RMP is designed to protect off-site people and the environment, whereas PSM is designed to protect on-site people. The RMP is required for plant sites that use more than a specified threshold quantity of regulated highly hazardous chemicals. The RMP is a site responsibility (the site may have several processes), whereas PSM covers every covered process on the site. The RMP has the following elements: + Hazard assessment + Prevention program + Emergency response program + Documentation that is maintained on the site and submitted to federal, state, and local authorities. This information is also shared with the local community.The RMP document is updated when the process or chemistry changes or when a governmental audit requests an update. The first three parts of the regulation are described briefly in the following paragraphs. The fourth part, documentation, is self-explanatory. Hazard assessment is a consequence analysis for a range of potential hazardous chemical releases, including the history of such releases at the facility. The releases must include the worst-case scenario and the more likely but significant accident release scenarios. A risk matrix can be used to characterize the worst-case and more likely scenarios The EPA requires the following consequence analyses: (1) A single worst-case release scenario is analyzed for all covered flammable materials on the site, and only one flammable substance is analyzed for other more likely scenarios; and (2) a single worst-case release scenario is analyzed for all toxic substances on the site, and more likely releases are analyzed for each toxic substance covered by the rule. The worst-case scenario is based on releasing the entire contents of a vessel or piping system ina 10- minute period under worst-case meteorological conditions (F stability and 1.5 n/s wind speed). Passive mitigation measures (for example, dikes) can be used in the calculation process; therefore the release rate for liquid spills corresponds to the evaporation rate. Alternative release cases for toxic substances cover scenarios with toxic concentrations beyond the fenceline. Alternative cases for flammable substances cover scenarios that may cause substantial damage off-site and on-site. The release scenarios that have a potential to reach the public are of the greatest concern. Those with no off-site potential damage are not required to be reported. Dispersion model calculations are normally used to estimate downwind concentrations; these concentrations are the basis for determining the consequences resulting from toxicity, fires, and/or explosions. For those not interested in using dispersion models, the standard includes lookup tables for all the listed substances to help a facility determine the impact distances for specific release scenarios. The RMP requires only an analysis of the consequence and not the probability. Therefore the results are not a true determination of risk, because risk is composed of both consequence and probability. A more detailed description of the required consequence analyses can be found elsewhere The second requirement of the RMP is a prevention program. The prevention program has 11 elements, compared to the 14 elements of the PSM standard. As shown in Table 3-5, many of these elements are duplicated. Fortunately, the EPA made a deliberate attempt to retain the same requirements wherever possible, although differences exist because the EPA and OSHA have different responsibilities. The first column in Table 3-5 lists each element of the PSM program, and the second column shows the corresponding element of the prevention program (some elements have no equivalence). Table 3-5. Comparison of the PSM and RMP Prevention ProgramsPSM program (OSHA) RMP (EPA) Process safety information Process safety information Process hazards analysis Hazard evaluation Operating procedures Standard operating procedures Employee participation (No equivalence) Training Training Contractors (No equivalence) Pre-startup review Pre-startup review Mechanical integrity Maintenance Hot work permit (No equivalence) Management of change Management of change Incident investigations Accident investigations mergeney response Safety audits (No equivalence) Risk assessment The emergency response program delineates the steps to be taken by the facility’s employees in response to accidental releases of hazardous materials. It also establishes procedures for notifying the local community and the appropriate emergency response agencies. Training is for all employees on the topics relevant to emergency response. The requirements include drills to test the plan and to evaluate its effectiveness, and the plan must be revised based on the findings of these drills. The plan must be coordinated with local emergency response plans developed by Local Emergency Planning Committees (LEPCs) and local emergency response agencies. As with similar OSHA regulations, the Resource Conservation and Recovery Act (RCRA), and the Spill Prevention Control under the Clean Water Act, the emergency response plan must be maintained at the facility and must include descriptions of all mitigating systems. DHS: Chemical Facility Anti-Terrorism Standards (CFATS) In 2006 Congress passed a law requiring the U.S. Department of Homeland Secuity (DHS) to establish risk-based performance standards for the security of chemical facilities. Subsequently, on April 9, 2007, DHS issued an interim rule called the Chemical Facility Anti-Terrorism Standards (CFATS). The details are provided in the Code of Federal Regulations 6 CFR 27. This rule applies to any facility that manufactures, uses, stores, distributes, or otherwise possesses certain chemicals at or above a specified quantity. Chemical plants contain assets, which include any person, environment, facility, material, information, business reputation, or activity that has a positive value for the company. The asset that is of the most concern with respect to chemical plants is the quantity of hazardous materials. A threat is any indication, circumstance, or event with the potential to cause the loss of, or damage to, an asset. A vulnerability is any weakness that can be exploited by an adversary to gain access to an asset. An adversary is any group, organization, or government that conducts, intends to conduct, or has the capability to conduct activities detrimental to critical assets4, Table 3-6 identifies some of the security issues of concern to chemical plants. The purpose of the CFATS rule is to identify to DHS all chemical facilities that are high-risk with respect to terrorismand to ensure that these facilities have an effective security risk management plan. Table 3-6. Security Issues of Concern to Chemical Plants Security issue Example terrorist objective Intentional loss of containment Release of chemicals to the atmosphere, resulting in toxic exposure, fire, or explosion. This public, to workers, and to the environment. The chemical plant can also be damaged or destroyed, causing direct or indirect economic damage. sults in harm to the Theft of chemicals Use of the chemicals as primary or secondary* improvised weapons against a third party. Contamination or spoilage Immediate or delayed harm to people or the environment, ofa product or proc ‘or to cause economic injury. De adation of the asset Mechanical or physical damage or cyber disruption. This causes severe direct or indirect economic damages. Acquisition of chemicals under Purcl fals 2 of chemicals through normal purchasing channels by pretense misrepresentation of purpose, Use of the chemicals as primary or secondary" improvised weapons against a third party. “A supporting or auxiliary weapo Adapted from David A. Moore, “Security,” pp, 23-104 to 23-109, The rule works as follows. The rule 6 CFR 27 includes Appendix A, which is a list of chemicals and threshold quantities. Ifa facility has these chemicals in quantities that exceed the threshold, they are required to complete a Chemical Security Assessment Tool (CSAT) Top Screen. The CSAT Top Screen is done on-line. DHS evaluates the Top Screen and makes a preliminary classification whether the facility poses a high risk. DHS ranks high-risk facilities into four tiers, 1 through 4, with tier 1 having the highest risk. All preliminarily tiered chemical facilities must subsequently conduct a Sccurity Vulnerability Assessment (SVA) and submit it to DHS. A security vulnerability assessment (SVA) is a process used to identify security issues arising from the facility’s activities, ranging from intentional release of chemicals, sabotage, to theft or diversion of chemicals that can be used as, or converted into, weapons. The SVA identifies these security issues and also allows the facility to estimate the likelihood of the facility’s vulnerabilities being successfully exploited. DHS evaluates the SVA and assigns a final tier ranking to the facility. with the purpose of supporting or supplementing the primary weapon. Chemical facilities in all four tiers are required to develop and implement a Site Security Plan (SSP) that meets criteria published in the risk-based performance standards. DHS conducts inspections and/or audits at ticred facilities, with the highest-risk facilities being inspected more frequently. The SSP must detail physical, procedural, and cyber measures that the site takes to reduce or eliminate the vulnerabilities. Security strategies for chemical facilities usually involve the following countermeasures for each security threat: deterrence, detection, delay, response, and awareness. Deterrence prevents or discourages security breaches by means of fear or doubt. Security guards, lighting, and barriers are examples of deterrence countermeasures. Cameras, monitoring, and intrusion alarms detect an adversary attempting to commit a security event.They may also provide the identity of the adversary, real-time observation, and possibly aid in apprehension of the adversary. The countermeasure of delay is designed to slow the progress of an adversary either coming into or out of a restricted area. Delay may provide the time required to interdict the attack or to apprehend the adversary. Response includes both facility response capability and the demonstrated capability of off-site responders, such as police and fire fighters. Response is not limited to armed interdiction by police and/or security personnel but also includes all the traditional hazardous materials response capability normally associated with safety and environmental stewardship. On-site response capabilities include fire fighting, security, medical response, spill containment, and the capability to quickly reduce inventory, to name a few. Awareness includes knowledge of your customers and the purpose of their purchase. This security strategy is designed mostly to prevent acquisition of chemicals under false pretense but can also identify inquiries from adversaries posing as customers in order to obtain information about your facility, raw materials, intermediates, or products. 3-2. Industrial Hygiene: Anticipation and Identification One of the major responsibilities of the industrial hygienist is to anticipate, identify, and solve potential health problems within plants. Chemical process technology, however, is so complex that this task requires the concerted efforts of industrial hygienists, process designers, operators, laboratory personnel, and management. The industrial hygienist helps the effectiveness of the overall program by working with these plant personnel. For these reasons industrial hygiene (particularly identification) must be a part of the education process of chemists, engineers, and managers. Many hazardous chemicals are handled safely on a daily basis within chemical plants. To achieve this operating success, all potential hazards must be identified and controlled. When toxic and/or flammable chemicals are handled, the potentially hazardous conditions may be numerous — in large plants there may be thousands. To be safe under these conditions requires discipline, skill, concern, and attention to detail. The identification step requires a thorough study of the chemical process, operating conditions, and operating procedures. The sources of information include process design descriptions, operating instructions, safety reviews, equipment vendor descriptions, information from chemical suppliers, and information from operating personnel. The quality of this identification step is often a function of the number of resources used and the quality of the questions asked. The different resources may have different operating and technical emphases unique to pieces of equipment or specific chemicals. In this identification step it is often necessary to collate and integrate the available information to identify new potential problems resulting from the combined effects of multiple exposures. During the identification step, the potential hazards and methods of contact are identified and recorded, As illustrated in Table 3-7, the potential hazards are numerous, especially because the listed hazards can also act in combination. This list of potential hazards together with the required data for hazard identification (see Table 3-8) is commonly used during the identification step of industrial hygiene projects. Table 3-7. Identification of Potential Hazards*Potential hazards Liquids Noise Vapors Radiation ‘Temperature Mechanical Entry mode of toxicants Inhalation Ingestion Body absorption (skin or eyes) Injection Potential damage Lungs Ears Nervous system Kidneys Reproductive organs Circulatory system Other organs 2 OlishifSki, Fundamentals of Industrial Hygiene, pp. 24-26. Table 3-8, Data Useful for Health Identification ‘Threshold limit values (TLVs) Odor threshold for vapors Physical state Vapor pressure of liquids Sensitivity of chemical to temperature or impact Rates and heats of reaction Hazardous by-prodt Reactivity with other chemicals Flammable and explosive concentrations of chemie: dusts, and vapors Noise levels of equipment ‘Types and degree of radiation Table 3-9 is a list of odor thresholds for various chemicals. This is one approach to identify the presence of chemical vapors in the workplace. Individuals vary greatly with respect to odor detection so great variability in this is expected, Also, some chemicals, like methyl ethyl ketone, anesthetize the olfactory organs with continued exposure, reducing the ability to detect the odor. In many cases the odor threshold is below the threshold limit value (TLV). For instance, chlorine has an odor threshold of 0.05 ppm while the TLV is 0.5 ppm (Appendix G). In this case the odor is noticed at a concentration well below the TLV. For some chemicals the reverse case is true. For instance, ethylene oxide has an odor threshold of 851 ppm while the TLV is 1 ppm. In this case once the odor is detected, the exposure limit has been greatly exceeded. Table 3-9. Odor Thresholds for Various Chemicals*