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Westlake, Lake Charles North

Parent Companies:
Axiall, LLC
EPA Facility ID:
100000169462
Other ID:
70669GRGGL1600V
Facility DUNS:
125661392
Parent Company DUNS:
555853949

Location:

Address:
1600 VCM Plant Road
Westlake, LA 70669
County:
CALCASIEU
Lat / Long:
30.252, -93.284 (Get map)
Method:
Interpolation - Photo
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Axiall, LLC
Phone:
(337) 708-5000
Address:
1600 VCM Plant Road
Westlake, LA 70669
Foreign Address:

Person responsible for RMP implementation:

Name:
Daniel Pund
Title:
Supervisor - HSE

Emergency contact:

Name:
Anthony Bonilla
Title:
Site Manager
Phone:
(337) 708-4305
24-hour phone:
(504) 415-7603
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(337) 708-5000
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
68
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
0520-00012-V0
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Dec. 3, 2009
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Unspecified process
RMP ID:
1000047201
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Vinyl chloride [Ethene, chloro-]
75-01-4
32,000,000
No
Hydrogen chloride (anhydrous) [Hydrochloric acid]
7647-01-0
721,000
No
Propylene [1-Propene]
115-07-1
80,000
No
Sulfur dioxide (anhydrous)
7446-09-5
16,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Daniel Pund
Address:
1300 PPG Drive
PO Boxs 1000
Lake Charles, LA 70602
Foreign Address:

Phone:
(337) 708-4095

Latest RMP Submission:

Date:
Jan. 21, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000038451

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Unspecified process)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Drains
  • Sumps
not considered:
  • Dikes
  • Enclosures
  • Berms

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Unspecified process)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Drains
  • Sumps
not considered:
  • Dikes
  • Enclosures
  • Berms
Active mitigation
considered:
  • Water curtain
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Unspecified process)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Unspecified process)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • Administrative Controls
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Unspecified process)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Water curtain

6. Five-year accident history

July 2, 2014 at 09:15
ID:
1000036938
NAICS:
Petrochemical Manufacturing (32511)
Duration:
1 hours and 37 minutes
Chemicals involved:
  • Hydrogen chloride (anhydrous) [Hydrochloric acid]
  • Vinyl chloride [Ethene, chloro-]
Release events:
Gas release
Weather conditions at time of event
Wind speed:
2.0 miles/h WSW
Temperature:
89.00 ℉
Atmospheric stability:
B
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
34
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Human error
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised maintenance
Jan. 6, 2011 at 14:05
ID:
1000031760
NAICS:
Petrochemical Manufacturing (32511)
Duration:
55 minutes
Chemicals involved:
  • Vinyl chloride [Ethene, chloro-]
  • Hydrogen chloride (anhydrous) [Hydrochloric acid]
Release events:
Fire
Weather conditions at time of event
Wind speed:
5.0 miles/h N
Temperature:
55.00 ℉
Atmospheric stability:
C
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$100000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Revised maintenance
  • Revised operating procedures

7. Prevention: Program level 3

, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000041022
Safety Review Date
Jan. 16, 2014, since latest RMP submission
PHA Update Date
Aug. 30, 2013, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Earthquake
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Dikes
  • Deluge System
  • Water Curtain
  • Neutralization
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 6, 2014, since latest RMP submission
Training Review Date
Jan. 16, 2014, since latest RMP submission
Maintenance Review Date
Dec. 2, 2013, since latest RMP submission
Maintenance Inspection Date
Sept. 12, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 26, 2013
Management of Change Review Date
Jan. 20, 2014
Pre-startup Review Date
Jan. 13, 2014
Compliance Audit Date
Aug. 29, 2013
Compliance Audit Change Completion Date
Dec. 31, 2014
Incident Investigation Date
July 3, 2014
Incident Invest. Change Completion Date
Dec. 31, 2014
Participation Plan Review Date
June 27, 2013
Hot Work Review Date
Jan. 8, 2014
Contractor Safety Review Date
June 27, 2013, since latest RMP submission
Contractor Safety Eval. Date
Dec. 30, 2013, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
April 25, 2013
Local Response Agency:
Local Response Agency Phone:
(337) 436-3354
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Environmental Protection Agency Risk Management Plan 11255 Louisiana



Executive Summary 17 January 2014



Georgia Gulf Lake Charles, LLC

1600 VCM Plant Road

Westlake, LA 70669



4013 LDEQ Agency Interest Number

Georgia Gulf Lake Charles, LLC

Risk Management Plan

Executive Summary



Georgia Gulf Lake Charles, LLC is committed to the safety of the workforce and the public. This commitment is demonstrated by the resources invested in accident prevention, training of highly qualified personnel, and considering safety in the design, installation, operation and maintenance of our facility process. Our policy is to implement reasonable controls to prevent chemical releases. However, if a release does occur, our personnel are trained and equipped to quickly respond to, control/contain, and mitigate the release.



Georgia Gulf Lake Charles, LLC is committed to the Responsible Care Management System program of the American Chemistry Council (ACC), a voluntary initiative for the safe management of chemicals and processes, and meeting the needs of our stakeholders. Georgia Gulf Lake Charles, LLC follows the Responsible Care Management System, which is integral to the development and implementation of our Environmental and Health and Safety policies. Georgia Gulf Lake Charles, LLC continues to improve our Community Awareness and Emergency Response Procedures to assist in emergency preparedness and foster community right to know. This is further demonstrated by Georgia Gulf Lake Charles, LLC's involvement in outside agencies and willingness to provide an open line of communication with the community.



Georgia Gulf Lake Charles, LLC is located in Westlake, Louisiana. The facility came into existence on November 13, 1999 as part of the Vinyls acquisition by Georgia Gulf Corporation and Affiliates from CONDEA Vista Company. Georgia Gulf Lake Charles, LLC is a producer of Vinyl Chloride Monomer (VCM). Regulated chemicals such as vinyl chloride monomer, hydrochloric
acid, sulfur dioxide, and propylene are used in the production process. Other regulated chemicals used in our process, which are in quantities below the threshold quantity include chlorine and ethylene.



Process Safety Information



Georgia Gulf Lake Charles, LLC maintains a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters, specific chemical inventories and equipment design basis/configuration information. Specific departments within the facility are assigned responsibility for maintaining up-to-date process safety information. Employees are provided training on how to locate the information from various computer terminals located throughout the plant.



Chemical specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in safety data sheets (SDS). This information is supplemented by documents that address known concerns and hazards associated with inadvertent mixing of specific chemicals. Georgia Gulf Lake Charles, LLC has documented safety-related limits for specific process parameters. The facility ensures that the process is maintained within these limits using process controls, monitoring instruments, protective instrument systems, and highly trained personnel.



Georgia Gulf Lake Charles, LLC maintains an electronic database accessible by both employees and contractor supervision, which provides information about the design and construction of process equipment. This information combined with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.



Process Hazard Analysis



Georgia Gulf Lake Charles, LLC has a comprehensive program to help ensure the hazar
ds associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.



The facility primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of employees who have operating and maintenance experience as well as engineering expertise. The team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.



The PHA team findings are made available to those individuals associated with the process unit for comments and forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest rank receive the proper level of attention. All approved mitigation options being implemented in response to PHA findings are tracked through completion. The final resolution of each finding is documented and retained.



Operating Procedures



Operators, supervisors, and plant engineers work together to develop and maintain operating procedures. These procedures define how tasks related to process operations are safely performed. At Georgia Gulf Lake Charles, LLC, operating procedures are: (1) used to train employees, and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets.



Operating procedures include:

- Steps for safely conducting activities,

- Applicable process safety information, such as safe operating limits,

- Safety and
health considerations, such as chemical hazards, personnel protective equipment required, and steps to take if exposed to a particular chemical.



Plant personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operation, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations.



Training



Georgia Gulf Lake Charles, LLC trains its workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training.



All new operators receive comprehensive training before being assigned to the operating unit. This training includes training on specific types of equipment, such as pumps and compressors, general overview of the process, properties and hazards associated with the substances in the process, detailed review of plant procedures, such as safe work practices and emergency response. Written tests are used to verify that employees understand the training material before a new employee can report to a process unit.



Once the new employee reports to the unit, detailed training with respect to the process and specific procedures is given to the employee. Once the new hire has demonstrated, through written tests and demonstration of learned skills, mastery of process specific operating procedures, the employee is allowed to begin work.



Refresher training covers (1) a general overview of the process, (2) the properties and hazards of the substances in the process and, (3) a detailed review of the process operating procedures and safe work practices. Written tests are used to verify that employees understand the training before an employee can resume work in the process. The operators have been consulted in safety meetings and through questionnaires regarding effectiveness and frequency of training. Recommendations are reviewed and changes to the training program are implemented as appr
opriate.



Management of Change



The Management of Change program for Georgia Gulf Lake Charles, LLC evaluates and approves all proposed changes to chemicals, equipment, and procedures for covered processes to help ensure that a change does not negatively affect safe operations. All changes that are deemed to be a true process change must be confirmed through a full management of change program to help ensure process safety information and procedures are updated, and affected employees are notified and trained, where applicable, of the change.



Pre-Startup Safety Review (PSSRs)



Georgia Gulf Lake Charles, LLC conducts a safety review of a new or modified process before the process is placed in service. The purpose of the PSSR is to ensure the safety features, procedures, personnel and equipment are appropriately prepared for startup prior to placing the equipment in service. The review provides an additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.



Mechanical Integrity



Georgia Gulf Lake Charles, LLC has well established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, emergency shutdown systems, and rotating equipment in a safe operating condition. The basic aspects of this program include (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies and, (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process.



Maintenance personnel receive training on (1) an overview of the proc
ess, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices. Written procedures help ensure that work is performed in consistent manner and provides a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits. If a deficiency is identified, the equipment will be repaired in a timely manner. All outstanding deficiencies are tracked until such time a final solution has been implemented and documented.



Another integral part of the mechanical integrity program is quality assurance. Georgia Gulf Lake Charles, LLC incorporates quality assurance into equipment purchase and repairs. This helps ensure that new equipment is suitable for intended use and that proper materials and spare parts are used when repairs are made.



Safe Work Practices



Georgia Gulf Lake Charles, LLC has an extensive safe work program in place to ensure worker safety. Examples of the program include (1) control of the entry/presence/exit of support personnel, (2) lockout/tagout procedures to ensure isolation of energy sources for equipment undergoing maintenance, (3) procedures for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedures to conduct heat/spark producing activities, and (5) a permit and procedures to ensure that adequate precautions are in place before entry into a confined space.



These procedures, along with training of affected personnel, help in defining a system to ensure that operations and maintenance activities are performed safely.



Incident Investigation



Georgia Gulf Lake Charles, LLC investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so similar incidents can be prevented using a root cause analysis process. Employees are trained to identify and re
port any incident requiring investigation. The initial investigation process is initiated within 48 hours of the incident. Depending on the incident, an investigation team may be formed. Results of the investigation are documented and tracked through completion.



Employee Participation



Georgia Gulf Lake Charles, LLC maintains a written employee participation program to help ensure that safety and environmental concerns of the plant workers are addressed. The facility utilizes an employee safety team to help address safety concerns and promote a pro-active safety culture that encourages active participation of personnel in safety, health, and environmental activities. Employees are consulted and/or informed about all aspects of the RMP prevention program including PHA's (Process Hazard Analysis), operating procedures and incident investigations.



Compliance Audits



Georgia Gulf Lake Charles, LLC audits the covered processes to ensure that the prevention programs are effectively addressing safety, health, and environmental issues. The facility utilizes employees knowledgable in the processes, such as the employee safety team, employees within the company, and to evaluate the RMP/PSM prevention programs to ensure they satisfy the requirements of the RMP/PSM rules, and whether the prevention programs are sufficient to ensure safe operation of the facility. The company also periodically hires 3rd party consultants to perform facility PSM/RMP audits. The results of the audit are documented, recommendations are resolved, and appropriate enhancements made to the operations of Georgia Gulf Lake Charles, LLC.



Contractors



Georgia Gulf Lake Charles, LLC has established a program to help ensure that contractor activities are performed in a safe manner. This program reviews the safety record of the contractors to ensure the plant only hires contractors who can safely perform the desired task. The facility communicates to the contractor supervisor the hazards of t
he process on which they and their employees will work, the plants safe work practices, and the plants emergency response procedures. The plant requires that the contractor supervisors train each of their employees on hazards and procedures specific to the site. The plant periodically reviews contractors training documents and work performances to help ensure that safe practices are followed.



Five Year Accident History



? On January 6, 2011 pump P-202B, the HCl column liquid feed pump experienced a seal leak and fire. The pump was isolated and the fire was extinguished by site ERT personnel. A reportable quantity release of 42 pounds of vinyl chloride monomer over a 55 minute period was experienced. No injuries or off-site impact resulted from the incident.



? On July 2, 2014 there was a leak in C-202 piping that resulted from the attemp to remove a blind that was outside the scope of a job being done by a contractor. There was a release of 345 lbs of anhydrous hydrogen chloride and 0.006 lb of vinyl chloride. There was only an off-site impact of this incident that resulted in a call for a shelter in place of approx 34 persons in an adjacent facility as a precautionary measure.



Emergency Response Program



Georgia Gulf Lake Charles, LLC's emergency response program has been developed to meet the emergency planning, response, and notification requirements of the following regulations:



- OSHA 29 CFR 1910.38 (a) - Employee Emergency Action Plans

- OSHA 29 CFR 1910.120 (q)-Hazardous Waste Operations and Emergency Response (HAZWOPER)

- OSHA 29 CFR 1910.110 (n) Process Safety Management of Highly Hazardous Chemicals

- OSHA 29 CFR 1910 Subpart L-Fire Protection

- LADEQ LAC 33:I 3901- Notification Regulations for Unauthorized Discharge

- LDPS Title 33, Part V, Subpart 2, Ch.1011-Release Reporting

- EPA 40 CFR Part 302.6- Notification Requirements

- EPA 40 CFR Part 355.40-Emergency Planning and Release Notification

- EPA 40 CFR Part 68- Risk Managem
ent Programs for Chemical Accidental Release Program

- EPA 40 CFR Part 355.30- Facility Coordinator and Emergency Response Plan

- EPA 40 CFR Part 112- Spill prevention, Control and Countermeasures Plan

- EPCRA 302- List of Extremely Hazardous Substances



The emergency response strategy for the facility is to prevent and/or control emergency situations via the use of engineering, design, and fixed protection systems. The plant has an Emergency Response Team that is available 24 hours per day, and trained to respond and take actions to contain, control, and mitigate any release that might occur. The team has access to on-site emergency equipment that is appropriate for situations that could possibly occur at the facility. Emergency Response Team drills are conducted to assess the emergency response effort at the facility and make modifications where appropriate. In addition to the considerable on-site resources, Georgia Gulf Lake Charles, LLC is a member of the Southwest Louisiana Mutual Aid Association. This membership allows the facility to draw on the emergency response resources of other industries in the immediate area.



The following is a partial listing of the equipment that is available for emergency response through Mutual Aid or On-site:

- Firepumps w/ fixed firewater system

- Fire Monitors

- Fire Extinguishers

- Dry Chemical Truck

- Foam Pumper

- Water Deluge Systems

- Fixed Extinguishing Systems

- Spill Response Unit



Georgia Gulf Lake Charles, LLC is a participant in the Calcasieu Parish Community Awareness and Emergency Response (CAER) group and the community planning process cooperating with the Calcasieu Parish Local Emergency Planning Committee. A copy of the plant's Emergency Response Plan has been forwarded to the Office of Emergency Preparedness per the requirements of 40 CFR 355.



Planned Changes to Improve Safety



Georgia Gulf Lake Charles, LLC constantly strives to improve safety and reduce risk through auditing, suggestion
s from employees, safety teams, incident investigations, and the use of proper engineering standards and specifications.