4
Juler Group Risk Management Newsletter The purpose of Juler Group is to safeguard life, property, the environment and sustainable business process. Its core competence is to identify, assess and advise on how to manage risk. Whether advising on how to best control hazardous exposures, or certifying a company’s management system, or advising how to best respond to competitive threat in the introduction of new innovative sustainable products, its focus is to safely and responsibly protect the current value of our clients’ organization and enhance their future value. Energy Industry – Oil & Gas Hazard Exposure Assessment & Risk Engineering Manufacturing surface and subsea wellhead drilling and exploration equipment requires the use of state of the art machining, welding and high pressure technologies. The variety of process steps requires many different chemical products and types of equipment to manufacture products capable of withstanding extreme environmental demands. Due to the nature of the work the potential for exposure to physical and chemical hazards is high and includes vibration, noise, toxic agents, cancer causing agents, mutagenic agents, radiation and other health hazards. Energy industry risk control managers with health, safety and environmental responsibility must demonstrate an understanding of all the hazards in their operations. HSE managers follow the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) requirement for employers to document their organizations understanding of all hazards in the workplace in compliance with 29 CFR 1910. The regulation also requires employers to plan to monitor and control the hazards, and to train employees under the hazard communication standard (29 CFR 1910.1200). The task to identify, assess and manage these risks can be quite complex, and in many cases HSE personnel perform this task at a superficial level. Many times, the assessment stops at the review of job tasks related to loss of limb and life by mechanical means. Hazards that are unseen or not easily understood are often ignored or not assessed due to lack of knowledge. To overcome this deficiency Juler Group has streamlined the hazard assessment process resulting in confident data and high quality documentation using our Qualitative - Quantitative Assessment Method (QAM) that results in a comprehensive hazard assessment that is systematic and reproducible. Juler Group performs QAM based Hazard Exposure Assessments to assist in the development of Industrial Hygiene monitoring strategies, medical surveillance strategies, process engineering control plans, Job Safety Analysis (JSA) documentation, employee training programs and to support legal defense. The following case highlights key outcomes resulting from the Juler Group QAM process. Juler Group performed multi-site hazard exposure assessment and risk engineering across four manufacturing, assembly, and service facilities. Machining, welding and assembly operations (Site 1) – QAM performed on over 2,090 potentially hazardous exposure agents across fifteen (15) manufacturing processes. Juler Group reduced Industrial Hygiene sampling labor and analytical costs by over 73%. Managing Risk in the Workplace Hazard Exposure Assessment & Risk Engineering Hazardous Noise Assessment & Hearing Conservation Program Management High Pressure Testing Competence Hazard Assessment and Training Program Development Hazard Exposure Assessment & Risk Engineering OSHA News EPA News Industry Focus News In this issue Newsletter 3Q2010 3Q2010 Newsletter - www.JulerGroup.com 512-228-9805 to the agent in the concentrations it is found? It is the responsibility of the employer to address these and many other issues in their written plan. To complete this task, an industrial hygiene risk based exposure assessment must be completed. Juler Group recommends that a qualitative and quantitative exposure risk based assessment model be used. The tool is called the Qualitative/Quantitative Assessment Method (QAM) and results in an Exposure Risk Rating (ERR) and a specific agents monitoring and control requirements. This stepwise procedure is systematic and reproducible resulting in reduced labor and analytical costs. The two basic steps in the QAM is as follows: Step 1: Qualitative Risk Based Exposure Assessment All agents are identified and analyzed in terms of process, job task and regulatory and non-regulatory limits. The output includes an calculated Exposure Risk Rating (ERR), and a professional judgment of exposure risk. The ERR allows the development of a prioritized monitoring plan of all potentially hazardous agents. This qualitative step constitutes “sampling” by the Agency and is fully compliant to the standard. Step 2: Quantitative Risk Based Exposure Assessment: Prioritized agents of concern are sampled to quantify employee exposure. This step allows the hygienist to determine if monitored agents are within regulatory/non-regulatory limits, and it may confirm or deny the need for further monitoring and controls. The QAM delivers a systematic, reproducible and documented method for assessing all agents that are identified. Without this analysis, the safety program may be deemed unacceptable and non- compliant. Without it, you (should be your) employees may be left exposed. Chemical Scoring & Ranking The Exposure Assessment Model (QAM) can now be used to expand the hazard assessment to include the chemical scoring and ranking system that allows A profile for potential chemicals of concern is generally thought to include persistence in the environment, potential to bio-accumulate, and ability to cause toxic effects at environmentally relevant concentrations. Juler Group has developed a Chemical Assessment Model (CAM) that combines the use of the Chemical Scoring and Ranking Assessment Model (SCRAM) and the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The results of the CAM are then bolted on to the QAM providing the industrial hygienist and environmental specialist a complete profile of an agent found in their operations. Data sources for our enhanced hazard model include the U.S. EPA Aggregated Computational Toxicology Resource (ACToR), the data bank of Environmental Properties of Chemicals (EnviChem), European Chemical Substances Information System (ESIS), the Result of the GHS Classification by the Japanese Government (GHS-J), the U.S. EPA High Production Volume Information System (HPVIS), the Hazardous Substances Databank (HSDB), the U.S. EPA Integrated Risk Information System (IRIS) and others. The value of the combined Exposure Assessment Model and Chemical Assessment Model include 1) highly targeted monitoring plans, 2) a history of use and substitution of chemical products, 3) a history of exposure and containment controls, 4) a full document suite for OSHA and EPA, and 5) reduced monitoring and analytical costs. An important resource to risk managers, the QAM-CAM may be used to communicate with employees, stakeholders and the public regarding compliance and sustainability initiatives. Contact Juler Group at 512.346.4800 for more information about the QAM and CAM risk based assessment tools. Upcoming Implications for Risk Management in light of the Deepwater Horizon Incident. Many reports and individual investigations and reports have been made regarding the Deepwater Horizon (Mississippi Canyon Block 252, Macondo Well) accident highlighting events, critical factors, technical problems, human error and management boondoggles. Juler Group principle, Robert Juler, has reviewed the numerous reports and presentations in an effort to deduce implications for risk management in the offshore and onshore drilling and exploration industry. Contact Robert Juler at 512.346.4800 ext. 701 to receive a copy of this analysis.

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Page 1: Juler Group Risk Management Newsletterjulergroup.com/brochures/JulerGroup3Q2010v6.pdf · 2019-04-19 · Juler Group Risk Management Newsletter The purpose of Juler Group is to safeguard

Juler Group Risk Management Newsletter The purpose of Juler Group is to

safeguard life, property, the environment

and sustainable business process. Its

core competence is to identify, assess

and advise on how to manage risk.

Whether advising on how to best control

hazardous exposures, or certifying

a company’s management system,

or advising how to best respond to

competitive threat in the introduction of

new innovative sustainable products,

its focus is to safely and responsibly

protect the current value of our clients’

organization and enhance their future

value.

Energy Industry – Oil & Gas

Hazard Exposure Assessment & Risk Engineering

Manufacturing surface and subsea

wellhead drilling and exploration

equipment requires the use of state of

the art machining, welding and high

pressure technologies. The variety of

process steps requires many different

chemical products and types of

equipment to manufacture products

capable of withstanding extreme

environmental demands. Due to the

nature of the work the potential for

exposure to physical and chemical

hazards is high and includes vibration,

noise, toxic agents, cancer causing

agents, mutagenic agents, radiation and

other health hazards.

Energy industry risk control managers

with health, safety and environmental

responsibility must demonstrate an

understanding of all the hazards in

their operations. HSE managers

follow the U.S. Department of Labor’s

Occupational Safety and Health

Administration (OSHA) requirement

for employers to document their

organizations understanding of all

hazards in the workplace in compliance

with 29 CFR 1910. The regulation

also requires employers to plan to

monitor and control the hazards, and

to train employees under the hazard

communication standard (29 CFR

1910.1200).

The task to identify, assess and manage

these risks can be quite complex, and in

many cases HSE personnel perform this

task at a superficial level. Many times,

the assessment stops at the review of

job tasks related to loss of limb and life

by mechanical means. Hazards that

are unseen or not easily understood are

often ignored or not assessed due to

lack of knowledge.

To overcome this deficiency Juler Group

has streamlined the hazard

assessment process resulting in

confident data and high quality

documentation using our Qualitative -

Quantitative Assessment Method (QAM)

that results in a comprehensive hazard

assessment that is systematic and

reproducible. Juler Group performs QAM

based Hazard Exposure Assessments

to assist in the development of Industrial

Hygiene monitoring strategies, medical

surveillance strategies, process

engineering control plans, Job Safety

Analysis (JSA) documentation, employee

training programs and to support legal

defense. The following case highlights

key outcomes resulting from the Juler

Group QAM process.

Juler Group performed multi-site

hazard exposure assessment and risk

engineering across four manufacturing,

assembly, and service facilities.

Machining, welding and assembly

operations (Site 1) – QAM performed

on over 2,090 potentially hazardous

exposure agents across fifteen (15)

manufacturing processes. Juler Group

reduced Industrial Hygiene sampling

labor and analytical costs by over 73%.

Managing Risk in the Workplace

Hazard Exposure Assessment & Risk EngineeringHazardous Noise Assessment & Hearing Conservation Program Management

High Pressure Testing Competence Hazard Assessment and Training Program DevelopmentHazard Exposure Assessment & Risk Engineering

OSHA NewsEPA NewsIndustry Focus News

In this issue

Newsletter 3Q2010

3Q2010 Newsletter - www.JulerGroup.com512-228-9805

to the agent in the concentrations it is

found?

It is the responsibility of the employer

to address these and many other

issues in their written plan. To complete

this task, an industrial hygiene risk

based exposure assessment must be

completed.

Juler Group recommends that a

qualitative and quantitative exposure risk

based assessment model be used. The

tool is called the Qualitative/Quantitative

Assessment Method (QAM) and results

in an Exposure Risk Rating (ERR) and a

specific agents monitoring and control

requirements. This stepwise procedure

is systematic and reproducible resulting

in reduced labor and analytical costs.

The two basic steps in the QAM is as

follows:

Step 1: Qualitative Risk Based Exposure AssessmentAll agents are identified and analyzed

in terms of process, job task and

regulatory and non-regulatory limits. The

output includes an calculated Exposure

Risk Rating (ERR), and a professional

judgment of exposure risk. The ERR

allows the development of a prioritized

monitoring plan of all potentially

hazardous agents. This qualitative step

constitutes “sampling” by the Agency

and is fully compliant to the standard.

Step 2: Quantitative Risk Based Exposure Assessment:

Prioritized agents of concern are

sampled to quantify employee exposure.

This step allows the hygienist to

determine if monitored agents are within

regulatory/non-regulatory limits, and it

may confirm or deny the need for further

monitoring and controls.

The QAM delivers a systematic,

reproducible and documented method

for assessing all agents that are

identified.

Without this analysis, the safety program

may be deemed unacceptable and non-

compliant. Without it, you (should be

your) employees may be left exposed.

Chemical Scoring & Ranking

The Exposure Assessment Model (QAM)

can now be used to expand the hazard

assessment to include the chemical

scoring and ranking system that allows

A profile for potential chemicals of

concern is generally thought to include

persistence in the environment, potential

to bio-accumulate, and ability to cause

toxic effects at environmentally relevant

concentrations.

Juler Group has developed a Chemical

Assessment Model (CAM) that combines

the use of the Chemical Scoring and

Ranking Assessment Model (SCRAM)

and the Globally Harmonized System of

Classification and Labeling of Chemicals

(GHS). The results of the CAM are then

bolted on to the QAM providing the

industrial hygienist and environmental

specialist a complete profile of an agent

found in their operations.

Data sources for our enhanced hazard

model include the U.S. EPA Aggregated

Computational Toxicology Resource

(ACToR), the data bank of Environmental

Properties of Chemicals (EnviChem),

European Chemical Substances

Information System (ESIS), the Result of

the GHS Classification by the Japanese

Government (GHS-J), the U.S. EPA High

Production Volume Information System

(HPVIS), the Hazardous Substances

Databank (HSDB), the U.S. EPA

Integrated Risk Information System (IRIS)

and others.

The value of the combined Exposure

Assessment Model and Chemical

Assessment Model include 1) highly

targeted monitoring plans, 2) a history

of use and substitution of chemical

products, 3) a history of exposure

and containment controls, 4) a full

document suite for OSHA and EPA, and

5) reduced monitoring and analytical

costs. An important resource to risk

managers, the QAM-CAM may be

used to communicate with employees,

stakeholders and the public regarding

compliance and sustainability initiatives.

Contact Juler Group at 512.346.4800

for more information about the QAM and

CAM risk based assessment tools.

UpcomingImplications for Risk Management in light

of the Deepwater Horizon Incident.

Many reports and individual

investigations and reports have been

made regarding the Deepwater

Horizon (Mississippi Canyon Block

252, Macondo Well) accident

highlighting events, critical factors,

technical problems, human error and

management boondoggles.

Juler Group principle, Robert Juler, has

reviewed the numerous reports and

presentations in an effort to deduce

implications for risk management in

the offshore and onshore drilling and

exploration industry. Contact Robert

Juler at 512.346.4800 ext. 701 to

receive a copy of this analysis.

Page 2: Juler Group Risk Management Newsletterjulergroup.com/brochures/JulerGroup3Q2010v6.pdf · 2019-04-19 · Juler Group Risk Management Newsletter The purpose of Juler Group is to safeguard

Refurbishment, assembly and test

operations (Site 2) - QAM performed

on over 395 potentially hazardous

exposure agents across six (6) customer

support processes. Juler Group reduced

Industrial Hygiene sampling labor and

analytical costs by over 89%.

Refurbishment, assembly and test

operations (Site 3) - QAM performed on

over 722 potentially hazardous exposure

agents across five (5) customer support

operations. Juler Group reduced

Industrial Hygiene sampling labor and

analytical costs by over 93%.

Compounding, extrusion, molding and

thermal-set operations (Site 4) - QAM

performed on over 389 potentially

hazardous exposure agents for rubber

processing operations including raw

materials, reacted and un-reacted

agents and “bloom” agents. Juler Group

reduced Industrial Hygiene sampling

labor and analytical costs by over 79%.

Exposure Assessment Milestones

Legal support; in-depth exposure

assessment and Industrial Hygiene

monitoring provided critical data and

documentation related to employee

complaints and potential litigation due to

an untimely death of former employee.

Process Procedures; in-depth exposure

assessment and process mapping

of the welding operations led to the

development of a manufacturing

process standard operating proceedures

document and Local Work Instruction

template in the utilization of portable

and fixed local exhaust ventilation (LEV)

systems for the reduction of toxic weld

fume.

Job Safety Analysis; results of risk

engineering analysis and exposure

assessment used extensively in job

hazard assessments to develop

comprehensive and compliant job safety

analyses documentation across all

manufacturing processes.

During the hazard assessment process

Juler Group performed the chemical

exposure assessment by using our

qualitative and quantitative exposure

analysis model that produces an

Exposure Risk Rating (ERR). The models

extensive algorithms take into account

100% of the chemical agents within a

chemical product formulation and their

regulatory and non-regulatory limits; the

data inputs come from the following data

sources:

• In-depth process knowledge regarding

control systems, job tasks, and similar

exposure groups,

• OSHA Permissible Exposure Limits

(PEL),

• American Conference of Governmental

Industrial Hygienists (ACGIH)

Threshold Limit Value (TLV),

• National Institutes for Occupational

Safety and Health (NIOSH)

Recommended Exposure Limit (REL),

• International Agency for Research on

Cancer (IARC) Cancer Classification

System, and

• United States National Laboratory of

Medicine Toxnet Toxicity Classification

System

Our industrial hygienists then incorporate

chemical category and physical state

characteristics to enable a professional

judgment of monitoring activity for

individual agents and complete the

Industrial Hygiene monitoring strategy.

The Juler Group Exposure Assessment

Model is systematic and reproducible

resulting in a monitoring strategy that

samples the right hazardous agent(s)

with the right number of statistically

significant samples. Advantages to the

Juler Group QAM Exposure Assessment

method include:

• A complete hazard assessment that is

documented and legally defensible,

• Allows the creation of a documented

prioritized Industrial Hygiene

monitoring strategy,

• Provides a complete visual history of

sampling, both qualitative and

quantitative, and

• Sampling labor costs and analytical

fees are reduced dramatically.

Hazardous Noise Assessment and Hearing Conservation Program Management Juler Group performed multi-state

multi-site comprehensive hazardous

noise assessment in customer service

operations in order to develop Hearing

Conservation Program, to achieve

and maintain compliance, to establish

medical surveillance (i.e. Hearing Tests)

during wide swings in workload, work

shift lengths, and process modifications.

Our noise engineers performed noise

monitoring by a stepwise process that

included sound level monitoring and

personal dosimetry. This was performed

in remote service centers and at remote

field service locations in the oil and gas

drilling and exploration industry. Juler

Group routinely “shadowed” field service

technicians in order to identify key tasks

leading to noise profiles with hazardous

continuous and impulsive noise.

Analysis of noise data suggests that

peak impulse noise (peak dBC) is

prevalent in oil and gas drilling and

department’s approach has shifted from

a focus on outreach and compliance to

an enforcement posture.

Under the CFATS regulations,

companies have to assess their

vulnerabilities, and the highest-risk

companies are required to develop site-

security plans and take other protective

measures. DHS then conducts audits

and inspections to ensure compliance.

Contact Juler Group regarding CFATS

Planning at 512.346.4800 ext. 701.

Industrial Threat & Vulnerability Management

Vulnerability assessments required

under the Environmental Management

Standards (EMS) – ISO 14001, have

traditionally been addressed as

“security.” However, since the War on

Terrorism and 9/11, the importance of

Vulnerability Assessments has been

elevated by operating facilities and falls

as a separate area of responsibility linked

to the EMS. This requires organizations

to develop plans for preventing or

mitigating terrorist or criminal actions

that could have significant impacts to the

national defense, the economy, or could

seriously affect local communities. A

review of the new International Standard,

ISO 31000:2009, Risk management

– Principles and guidelines, will help

organizations manage this risk more

effectively.

Contact Juler Group regarding Threat &

Vulnerability Planning and Management

Systems Development at 512.346.4800.

Commentary

Leadership & Ethics In Tough Times

This year was to be a year of transition

coming out of the recession that saw

a dramatic drop in oil and gas drilling

exploration and production. The

transition was interrupted by Deepwater

Horizon disaster in the Gulf of Mexico.

This event, coupled with management

demands resulting from the downturn

has levied unprecedented challenges

for leaders and managers in the oil and

gas industry. Organizations up and

down the supply chain are now wrestling

with restructuring, increased demand

with downsized workforces, mergers

and a host of new regulations. How do

industry leaders and managers lead from

here?

Leading in tough and transitory times

takes ingenuity and a revived spirit to

achieve success and there are some

basic elements that will help:

• A leader must communicate a vision

that represents an ideal that sets the

organization proudly apart from others,

emphasizes the future, and focuses on

innovation,

• A leader must communicate a clear

mission and respond to inquiries

quickly,

• A leader must tell the Truth! Continue

to develop trust that may have been

damaged,

• A leader must communicate

incessantly – people need and deserve

plenty of information about what’s

happening, why it’s happening, and

what are the next steps,

• A leader must understand the role

as leader, be competent and be visible

while navigating tough and turbulent

times. Seeing and hearing the leader is

of utmost importance.

Preparation for the Future

The oil and gas industry will emerge

smarter, stronger and more resilient in

the future. The time to create it is now.

Juler Group Leadership and Ethics

Group provide training and coaching

for leaders and managers in the energy,

pharmaceutical, semiconductor and

aerospace industries. Contact Juler

Group at 512-346-8400 ext. 710.

Industrial Hygiene & Environmental Innovation

Exposure Assessment Model and Chemical Scoring System

OSHA standards (29 CFR 1903,

1910) require employers to develop

safety plans that include exposure

assessments enabling them to eliminate

or minimize employee exposure to

harmful agents. Employers are required

to determine the type of hazards,

the potential for exposure, the extent

of exposure, the consequences of

exposure, the emergency response

to exposure, and the mitigation of the

exposure risk. In addition the standard

requires safety plans to be documented

and communicated to employees for all

locations where these exposures may be

present. The assessment must answer

some basic questions:

• Does a chemical component, with

an OSHA Permissible Exposure Limit

(PEL), pose a significant risk of

employee exposure within your

operations?

• Does this chemical component require

ongoing monitoring to determine if it

exceeds the PEL?

• Do you provide the correct PPE for

your employees to eliminate exposure

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for operations technicians in support of

aircraft maintenance operations.

• Designed and delivered a

training program for Leadership &

Ethics in communication,

collaboration, and succession

planning for an international non-profit

organization. Key desires were

creating uniform message and content

across functions.

• Designed and delivered a training

program for multi-cultural leaders

in an all-volunteer organization.

Training topics included cross-

cultural challenges, leadership

values, leadership skills and

volunteer motivation. Key drivers

were integrating western management

and leadership concepts with Asian

philosophies and concepts, and

motivation strategies in an all-volunteer

organization.

OSHA NewsCranes and Derricks – the November

08, 2010 deadline for compliance is

fast approaching for the new Cranes

and Derrick standard. The rule,

published in the August 9 Federal

Register, addresses critically important

requirements for crane operator

qualification and certification, crane

inspection, and set-up and disassembly.

The operator qualification and

certification section of the rule is 29 CFR

1926.1427, while the training section is

1926.1430.

Contact Robert Juler regarding Boss

Hog Crane and Rigger Training at

512.346.4800 extension 701.

EPA NewsGulf Oil Spill Response – The United States Environmental

Protection Agency has set up a website

highlighting activities related to the

environmental recovery resulting from

the deepwater Horizon oil spill incident in

the Gulf of Mexico. Please visit the EPA

site at http://www.epa.gov/bpspill/.

Industry Focus News Energy: Oil & GasBP’s report to congress and the

Bureau of Ocean Energy Management,

Regulation and Enforcement covers

many critical factors including the

following technical problems:

• Loss of integrity of the well casing,

• Unrecognized well conditions; reservoir

communication, HC influx (three flow

indicators- flow in , flow out, and DP

pressure) and failure to control well by

the crew,

• BOP failed to isolate source, and

• Ignition of Hydrocarbons

It is the opinion of Juler Group that

the incident may have been minimized

and concluded in a shorter time frame

by thorough risk planning including

exhaustive scenario and contingency

planning.

Juler Group recommends that oil

and gas exploration teams set aside

overconfidence and the erroneous

perceptions that planning for

catastrophic failure is an admission of

failure. Thorough contingency planning is

prudent risk management.

Contact Juler Group regarding Process

Safety Management and Contingency

Planning at 512.346.4800 ext. 701.

Energy: Wind Power

Green energy initiatives are driving this

industry segment. The fast growth of

this industry brings many challenges

for Health, Safety and Environmental

professional. From composite turbine

blade manufacturing, to machined

turbine components, to onshore

and offshore site selection and its

environmental conservation, to

installation and maintenance.

The National Conference of State

Legislatures indicates the in 2009 over

2,000 bills were introduced regarding

renewable energy. New solutions,

methods and training are required for

areas such working at extreme height,

working in confined spaces at height,

crane operations at height, emergency

response in remote locations and over

water.

Contact Juler Group regarding Wind

Energy Risk Control at 512.346.4800

ext. 701.

Department of Homeland Security: CFATS

Chemical Facility Anti-Terrorism - the

first-ever security regulation of the

chemical sector, the Chemical Facilities

Anti-Terrorism Standards (CFATS), aimed

at terror mitigation by the Department

of Homeland Security. These standards

take a risk-based approach to regulating

chemical companies, organizing them

into tiers according to the potential

dangers of the chemical processes.

In June 2010 DHS took enforcement

action for the first time against

chemical facilities for noncompliance

with the CFATS regulations. The June

actions signal to the industry that the

1Q2010 Newsletter - www.JulerGroup.com512-228-9805

exploration operations. During drilling

operations when field service technicians

install tubing heads, blowout preventers,

or other wellhead components, the

data shows that all types of hazardous

noise is common. It is interesting to

note that during wellhead replacement,

maintenance and rework operations

field service technicians are exposed

to hazardous noise levels even when

there is no drilling rig on site. The data

also shows the number of impulse

peaks that exceed the OSHA regulation

(140dBC) is high, even when the eight

hour Time Weighted Average (TWA) is

below the Action Level of 85 dBA, and

that the number of impulse peaks above

120dBC is quite large in all cases of 8-hr

TWA data sets.

In response to the hazardous noise

assessments a multi-state multi-

site hearing conservation program

management was developed and

implemented across division boundaries.

Juler Group managed the HCP including

full documentation suite, hearing

test provider qualification and audit,

threshold shift follow-up management,

professional supervisor, training audit

and HCP program audit within a Total

Quality Management (TQM) framework.

Key outcomes of the noise assessments

and HCP management include the

1) selection of the proper personal

protective equipment (PPE) for

hearing protection reducing exposure

to continuous and impulsive noise,

2) identification of noise reduction

techniques, and engineering controls. In

addition, annual hearing tests required

under HCP policy are managed through

pre-approved, annually audited hearing

test providers with fixed-base high

quality test facilities that have resulted

in greater accuracy and reproducibility

of patient audiograms, and greater

confidence in the analysis of standard

threshold shifts and noise induced

hearing loss.

High Pressure Testing Competence Hazard Assessment and Training Program DevelopmentJuler Group performed in-depth hazard

assessment and risk engineering

on multi-platform high pressure

testing. The effort was taken to

develop comprehensive JHA and

JSA documentation leading to the

development of a multinational, multi-

lingual competency-training program.

The assessment was conducted in high

pressure testing operations ranging

from 500 – 75,000psi over nine (9)

test platforms in manufacturing and

customer service functions. During

the assessment it was discovered that

testing operations conducted on a

customer site required its own unique

comprehensive risk control strategy with

additional risk mitigation procedures.

Key outcomes of the pressure testing

operations assessments included a

certified competency training program,

personnel communications plan,

site control and signage, situational

awareness training, personnel training,

subcontractor training and awareness,

non-essential personnel and site control

policy, emergency response plans,

insurance, security and contract dispute

management.

Energy Industry - Wind Manufacturing wind turbines for the

collection of renewable wind energy

through wind farms requires the use

of state of the art machining, welding,

composites compounding and stress

technologies. A variety of process steps

in the fabrication of turbine motors,

towers, and generator blades require

many different chemical products and

types of equipment to manufacture

products capable of standing up to

severe environmental impacts. Due to

the diversity of the work the potential

for exposure to hazardous agents is

high and includes toxic agents, cancer

causing agents, mutagenic agents,

radiation, vibration, noise and other

health hazards.

The same OSHA regulations demanded

in the Oil & Gas Industry apply in the

Wind Energy Industry. The following

case highlights key issues resulting from

the Juler Group QAM process.

Juler Group performed hazardous

exposure assessment in Wind Turbine

Blade Manufacturing operations for

over 31 potentially hazardous agents

across three (3) polymer composite

manufacturing processes. Juler Group

reduced Industrial Hygiene sampling

labor and analytical costs by over 23%.

Aerospace Industry

Hazard Exposure Assessment & Risk EngineeringThe private sector space flight industry

is growing at a good pace by providing

launch services for very small Earth

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observation satellites, communication

satellites, commercial resupply services

and scientific payloads. In the effort to

provide highly reliable and robust rocket

and payload systems the industry must

manufacture and test such systems

very rigorously. Many processing and

testing steps are taken that use cutting

edge systems with highly volatile and

flammable products in addition to more

traditional processes of machining,

fabrication, composites, welding,

assembly and test.

The same OSHA regulations demanded

in the Oil & Gas and Wind energy

industries apply in the private space

travel industry. Juler Group has provided

professional consulting and contracted

services for key players in this market.

The following highlights are a result from

the Juler Group QAM process.

Juler Group industrial hygiene team

performed Hexavalent Chrome

monitoring for indoor and outdoor

welding operations that included

standard fixture welding and welding

on engine test stand fuel systems.

This assessment and monitoring

required job hazard assessment and

JSA documentation outcomes that

mandated additional safety steps in the

proper purging and confirmation of the

absence of highly volatile fuels.

Juler Group conducted hazardous noise

assessments and hearing conservation

program audit for rocket engine test

operations. Monitoring was carried out

throughout the facility during normal

operations and during engine test.

Juler Group occupational safety team

conducted a safety assessment and

gap analysis of welding operations at

elevated heights on stationary engine

fueling platforms and aerial man lifts.

Process Safety Management

Juler Group professional process

safety team performed Process Safety

Management (PSM) gap analysis and

prioritization in accordance with OSHA

29 CFR 1910.119.

The operations where PSM initiatives

were undertaken include new rocket

engine test facilities consisting of

redundant systems with over 80 nodes

utilizing highly explosive and flammable

rocket grade propellants for heavy lift

transport.

Key components of the PSM included

test article installation and removal,

propellant loading and circulation,

oxidizer loading, propellant conditioning,

test firing, emergency response,

post-test procedures, site shutdown,

maintenance, and site inspection.

The PSM process resulted in a thorough

process hazard analysis (PHA) with

Failure Modes Effects Analysis, detailed

maintenance program, detailed RMP/

ERP plan, and effective Management of

Change (MOC) process.

Municipality - Hazardous Waste Industry

Hazard Exposure Assessment & Risk EngineeringJuler Group Environmental and Industrial

Hygiene team conducted hazardous

agent exposure assessment of over 58

potentially hazardous agents across

four (4) customer service operations

performed in municipal household

hazardous waste collection operations.

Juler Group reduced Industrial Hygiene

sampling labor and analytical costs by

over 90%.

Monitoring activities were related to

medical surveillance program results,

employee complaint resolution and

litigation support. Sampling centered on

the hazardous agent Arsenic. Additional

agents included DSMA, MSMA,

MEK, Cadmium, Chlorpyrifos, volatile

organics, and potential by-products from

decomposition and mixing.

General Industrial Hygiene - Strategy & Monitoring

Juler Group technical experts and pump

jockeys routinely perform breathing zone

monitoring, dermal exposure monitoring

and Hand-Arm/Whole-Body vibration

assessments in the support of Industrial

Hygiene initiatives.

Environmental Plans & Monitoring

Juler Group environmental professionals

routinely assist clients in achieving clean

air and storm water compliance. Some

recent highlights include: 1Q2010 Newsletter - www.JulerGroup.com512-228-9805

• Environmental site assessment -

Phase 1 gap analysis review

for remote upstream oil & gas service

centers across western United States,

• Storm Water Pollution Prevention

Program (SWPPP) review for remote

upstream oil & gas service centers

across western United States,

• SWPPP review for aerospace cargo

transport testing facilities,

• Airs permit prioritization of issues

in machining and manufacturing

operations, and

• Spill Prevention and Control and

Countermeasure (SPCC) assessment

and guidance in rocket engine testing

facilities.

Risk Engineering Consultancy

Juler Group risk mitigation professionals

are routinely engaged in gap analysis,

prioritization of issues, compliance

programming and project management

in support of risk management initiatives.

Highlights from our team include:

• Proprietary review of sustainability

assessment in the non-renewable

energy sector. Key issues within this

sector include operational excellence,

expansion of core business, and the

development of innovative products

and collaborative partnerships.

Additional highlights consist of public

perception of ethics and responsibility,

environmental conservation and

climate change, capabilities and

attitude of employees, and adherence

to internal standards.

• Proprietary review of changing risk

management issues in the energy

industry in the wake of the deepwater

horizon incident. Key issues comprise

accountability and transparency,

management commitment, regulatory

oversight and compliance, and

training.

• Industry review of health, safety

and environmental hazards

and controls for the Wind

Power Energy Industry valuechain.

Key issues take into consideration

construction commissioning and

decommissioning, wind farm

operation, occupational safety

at extreme height and confined

space in remote locations,

advanced polymer manufacturing and

infrastructure threat and security. Juler

Group opinion highlights the need for a

comprehensive and standardized

safety training package unique to the

wind energy industry.

• Proprietary survey of heavy equipment

compliance training outcomes. Issues

include learning modes, knowledge

assessment, skill and competence

assessment, productivity

training, and compliance training

shortcomings. The study showed that

current compliance training courses by

vendors were consistently

compromised due to employer time

constraints. Employers generally view

compliance training as providing little

value above compliance.

Juler Group Training Professionals

Juler Group risk control and safety

training professionals perform enhanced

training that adheres to our philosophy

of “competency - going beyond

compliance.” Both standard and

custom training programs are always

delivered with three components;

1) compliance, 2) competence and

3) productivity.

To meet our training objectives Juler

Group has developed training programs

to increase information breadth and

relevance, information retention, and

information understanding.

Our trainers and evaluators meet the

objective of competence by ensuring

that all participants are challenged

regardless of their individual level of

education and experience, native and

2nd languages, or their literacy issues.

In other words, we do not “dumb down”

the content or examinations to pass

every trainee. This philosophy ensures

we meet our competence objective

every time.

To meet our relevance and

understanding objective all required

compliance course sections are

enhanced with custom industry content,

lessons learned, best practices, and

audit outcome information.

To meet our productivity objective

Juler Group course developers include

industry best practices, standard

operating procedure analysis, six sigma

operations analysis information, and

general business principles of cost.

Courses are described as “intense”

and “very thorough.” Participants upon

completion have gained a greater

respect for the subject matter, and

most importantly their individual and

personal respect is enhanced. The

additional time required is minimal when

compared to the increased competence

and productivity trainees have displayed

when back in the work place.

Highlights of Juler Group training include:

• Designed and delivered multi-

state multi-division compliance

and competency based training in

heavy equipment operations for

remote service centers and field

service teams. Key drivers were

remote employees that would benefit

from standardized and customized

content, and uniform high quality

course delivery.

• Designed and delivered FAA/FAR

hazardous waste refresher training

Analyte Analyte

Hexavalent Chrome 1,3-Butadiene

Manganese Acrylonitrile

Beryllium 4-Vinyl-1-Cyclohexene

Cadmium Metal Working Fluids

Lead Isocyanates

Silica, Quartz Volatile Organics

Arsenic Toxins & Bioagents

Continuous Noise New Chemical Entities

Impulse Noise New Biological Entities

NORM Vibration

Non-Ionizing Radiation Non-Ionizing Radiation