6/18/07 - EXPEDITED SETTLEMENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $540. ALLEGED VIOLATIONS: RESPONDENT DID NOT PROVIDE EVIDENCE THAT IT:
HAS UPDATED AND REVALIDATED THE PROCESS HAZARD ANALYSIS AT LEAST EVERY 5 YRS AS REQUIRED BY 40 CFR 68.67(f);
HAS ANNUALLY CERTIFIED THE OPERATING PROCEDURES (I.E., THAT THE PROCEDURES ARE CURRENT AND ACCURATE) ON AN ANNUAL BASIS AS REQUIRED BY 40 CFR 68.69(c);
HAD PROVIDED REFRESHER TRAINING, AT LEAST EVERY 3 YRS, TO EACH EMPLOYEE INVOLVED IN OPERATING ITS PROCESS TO ASSURE THAT EACH EMPLOYEE UNDERSTANDS AND ADHERES TO THE CURRENT OPERATING PROCEDURES OF THE PROCESS AS REQUIRED BY 40 CFR 68.71(b);
HAS MAINTAINED TRAINING RECORDS INDICATING EACH EMPLOYEE'S IDENTITY, THE DATE OF TRAINING, AND THE MEANS USED TO VERIFY THAT EACH EMPLOYEE UNDERSTOOD THE TRAINING AS REQUIRED BY 40 CFR 68.71(c); AND
AT LEAST EVERY 3 YRS RESPONDENT HAS EVALUATED ITS COMPLIANCE WITH THE PREVENT PROGRAM REQUIREMENTS AND CERTIFIED THAT ITS PROCEDURES AND PRACTICES ARE ADEQUATE AND ARE BEING FOLLOWED AS REQUIRED BY 40 CFR 68.79(a).