Nebraska Ethanol Partnership Overview

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Nebraska Ethanol PartnershipOverview

• Doug Fletcher, CIH, CSP
• 402.553.0171
• fletcher.doug_at_dol.gov

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Who?

• All operational EtOH facilities.
• Under construction may participate in outreach.
• NE Ethanol Board
• OSHA Consultation
• OSHA
• Desired stakeholders

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Why Ethanol Producers?

• CPL 03-00-004
• Petroleum Refinery PSM National Emphasis Program
• Effective Date June 7, 2007
• Chemical processing and bio-refineries
• Tremendous growth of industry in NE!!

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Goals

• Minimize potential for catastrophic incidents
• Adequate emergency response planning training
• Reduce (group) TCIR and DART by 10 and 5 at the
  end of two year program.

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Participants will

• Provide documentation to OSHA that their chemical
  process safety program follows recognized and
  generally accepted good engineering practices
  i.e., through PHAs, SOPs, training, mechanical
  integrity programs, etc.
• Develop and implement an emergency response plan
  or emergency action plan, as appropriate.
• Conduct self-audits

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Participants will

• Identify training needs and conduct training
  accordingly.
• Provide injury illness data to OSHA (plus 2005
  and 2006, as available).
• Provide annual report (see attachment).
• Explore VPP or SHARP participation.

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Benefits

• Outreach training
• Bi-monthly OSHA, SMEs, partners, Consultation,
  others.
• 6 month deferral from programmed inspections
• Limited scope inspections if Consultation visit
  w/in past year.
• PSM, ER/EAP, HC, LOTO
• Penalty reductions
• 24-month deferral if inspected

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Verification

• Off-site, non-enforcement application materials
  and annual reports. All partners.
• On-site, non-enforcement OSHA Consultation.
  Eligible partners.
• On-site, enforcement Random, 1 20 of
  operating plants in Nebraska. Partners and
  non-partners.
• Unprogrammed activities per FIRM.

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Employee Involvement

• All employee rights preserved.employers not
  absolved of responsibility to comply with rules
  and regulations.
• Inform employees of partnership.
• Safety and health suggestion system.
• Involve ees in development, implementation, and
  evaluation of safety rules, policies, and
  procedures.
• Safety and health committee composed of
  cross-section of employees and management from
  various departments.

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