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Robert Lopez [EHD] <br /> From: Robert Lopez [EHD] <br /> Sent: Tuesday, May 31, 2022 10:31 AM <br /> To: Lauren Taylor <br /> Subject: PR0521885;Arrow Sign Co Hazardous Materials Program Inspection Compliance Review <br /> Attachments: Emergnecy Response Contingency Plan Template 012220.pdf; Sample Training Record <br /> Form 110719.pdf <br /> Lauren Taylor, <br /> I have reviewed the CERS submittal and compliance status and have found the following issues: <br /> • Violation #5—the hazardous materials inventory is not complete/up to date. <br /> 1. Acetone—the storage pressure and the storage temperature data elements have not been completed. <br /> • Violation #6,the site map does not show or address the following: <br /> 1. Internal roads. <br /> 2. The location of the acetylene, argon, carbon dioxide, paint and paint thinner is not shown (welding tanks <br /> will not suffice). <br /> A site map shall contain a north orientation, loading areas, internal roads, adjacent streets, storm and sewer drains, <br /> access and exit points, emergency shutoffs, evacuation staging areas, hazardous material handling and storage areas, <br /> and emergency response equipment. If a site map element is not applicable for your facility then list it on the map and <br /> label as "NA". <br /> • Violation #7, employee training records were uploaded in lieu of an Emergency Response/Contingency Plan <br /> (see attached template). <br /> - A business plan shall include the following emergency response procedures for a release or threatened <br /> release of hazardous materials, including, but not limited to,the following: <br /> i. immediate notification of local emergency personnel and the Environmental Health Department <br /> (EHD) <br /> ii. procedures for the mitigation of a release or threatened release to minimize any potential harm <br /> or damage to persons, property, or the environment <br /> iii. evacuation plans and procedures, including immediate notice,for the site <br /> • Violation #8, employee training records were uploaded in lieu of an Employee Training Plan. <br /> - A training plan must address training for all new employees and annual training, including <br /> refresher courses,for all employees in safety procedures in the event of a release or threatened release <br /> of a hazardous material, including, but not limited to: <br /> 1. Familiarity with the emergency response plans and procedures in the event of a release or <br /> threatened release of a hazardous material. <br /> 1 <br />