COURSE: Guidance Manual Training      

SUBJECT: Lesson 8      Procedures and Forms


DATE PREPARED:        9/24/99; nc 10/31/99

TRAINING AIDS: Overhead transparencies,  Projector





    Main Points


                                       Instructor Comments






OH #1


Title Page and Introduction



A number of forms and procedures are included in Chapter 9 of the Guidance Manual as aids and guides to help comply with the Hazardous Materials Ordinance.  They are straight-forward, but we will take a look at each.






OH #3




The forms and procedures in Chapter 9 are:

Permit Application Form -1p

Request for Variance from Secondary Containment Form -1 p

Appeal of Application Denial Form - 1 p

HMIS Preparation Guide and forms - 6 p

Discharge Reporting Procedures -2 p

DOT Form F 5800.1 (Rev. 6/89) - 2 p

ERP Preparation Guide - 5 p

Preparation Guide for Employee Training Records -1 p

Compliance Inspection Checklist -1 p






OH #3


Permit Application Form


Instructor show overhead of Permit Application Form


Hazardous materials storage facilities applying for initial permits, permit renewals, permit modifications or provisional or temporary permits after the date of issue of this manual must use the “Permit Application Form” included herein.  The “Permit Application Form” includes a “For Official use Only” section which the LFD will use to record the approval or disapproval of the application.  A copy of this page will be returned to the applicant by the LFD. 


Are there any questions?






OH #4


Request for Variance from Secondary Containment Form


Instructor show overhead of

Request for Variance from Secondary Containment Form


Per 33-18.16A.2, a person or entity may apply for a variance from the secondary containment requirements if the applicant can demonstrate that the requirement of secondary containment

           creates an unusual and particular hardship;

           proposes an alternative with equivalent protection; and

           the proposed alternative is certified as providing an equivalent degree of protection by a qualified independent engineer professionally registered in Texas and retained in accordance with §33-16.4.






OH #5


Appeal of Application Denial Form


Instructor show overhead of Appeal of Application Denial Form


If an application for

           an initial permit,

           a permit renewal,

           a permit modification,

           a provisional or temporary permit, or

           an application for a variance from secondary containment is denied,

the applicant may appeal the decision to deny to the CEC.  This form will serve as the cover sheet for such an appeal.






OH #6


HMIS Submission cover sheet


Instructor show overhead of  “page 1 of ____” form of the

HMIS Preparation Guide and forms -6  p


The ordinance requires the submission of an HMIS along with the submission of a permit application.  This preparation guide is based on the SFPC, the inventory reporting procedures established by San Diego, CA for its hazardous materials management program, and on the EPA’s Tier II reporting requirements.  The intent is to make the Laredo HMIS reporting relatively easy , but at the same time put the information in a form that is easily transposed onto (or from) a Tier II report.  If you already have the information of a Tier II form, you may use that form to submit the information.  Use the “Page 1" form ad the cover sheet for your submission.






OH #7


Discharge Reporting Procedures


Instructor refer to Discharge Reporting Procedures in GM.  No need to use overhead


Unauthorized discharges of hazardous materials from long term, short term or temporary storage facilities must be immediately reported to the Laredo Fire Department if the discharge is more than just a “recordable unauthorized discharge”. 


Certain hazardous materials incidents (or spills) must also be reported to the National Response Center, and in certain instances detailed written reports must also be filed.  This procedure describes the reports required for the LFD, and outlines certain other reports that may be required.






OH #8


DOT Form F 5800.1


Instructor show overhead of first page of

DOT Form F 5800.1 (Rev. 6/89) - 2 p

This is the form DOT requires for detailed incident reports in cases where they are required.  Tell where to get forms.






OH #9



Preparation Guide


Instructor show overhead of first page of ERP Preparation Guide -5 p


A facility must file an ERP as part of its HMMP.  The ERP must be a plan that is effective for the facility, and there is therefore no fixed procedure for its preparation.  This “Guide” may prove useful.  It calls for the inclusion of the following sections:

           a First Response Procedure;

           an Employee Notification Procedure;

           an Employee Response Procedure;

           information on Evacuation Routes, Emergency Exits, and Staging Areas;

           a Spill Mitigation Procedure;

           an Emergency Equipment Record;

           a Preparedness Checklist; and

           Agency Notification Procedures and Telephone Numbers. 


The user is also referred to OSHA’s 29 CFR 1910.38 for minimum standards for OSHA required fire prevention plans; and, in the appendix, provides a non-mandatory guideline to assist employers in preparing an emergency action plan.






OH #10


Preparation Guide for Employee Training Records


Instructor show overhead of Preparation Guide for Employee Training Records -1 p


           must provide training to employees,

           must keep records of training performed, and

           must make the training records and certifications available for inspection by LFD. 

This document provides a suggested format for maintaining employee training records.






OH #11


Compliance Inspection Checklist


Instructor show overhead of Compliance Inspection Checklist -1 p


This is a checklist that will be utilized by the LFD as it carries out compliance inspections of storage facilities.  The list may change from time-to-time, and LFD inspections for non-compliance are not limited by the publishing of this list.






OH #12


Summary & Questions