Chilton Consulting Group
P.O. Box 129
Rocky face, GA 30740
Office: 706-694-8325 Fax: 706-694-8316 email: chilton@alltel.net
April 2008
“Compliance and Performance”
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A COMPILATION OF NEWS ARTICLES AND EMERGING REGULATORY ISSUES AFFECTING THE SAFETY of the MEAT AND POULTRY INDUSTRY
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Announcements from Chilton Consulting Group
We have so much going on, Jeff Chilton is excited to be dedicating his full attention to the consulting group to grow our business and help clients assure compliance and maximize profits! Please read all the announcements below to see what is happening new this month:
We look forward to 2008 being a successful and prosperous year for our company and all our clients.
Contact Jeff Chilton for more information on any of these new services. Chilton Consulting Group will be expanding considerably in 2008 while continuing to provide exceptional service as always for HACCP improvements and regulatory compliance.
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OSHA Required Recordkeeping
Everyone knows about the OSHA 300 Log that must be kept up to date and the corresponding summary that is due from February through April every year. However, this is just one of many of OSHA’s recordkeeping requirements. Here is a list of others that also require recordkeeping, many of which you may be responsible.
--Written hazard communication plan—Emergency contingency plan --HAZWOPER safety and health programs--Training records --Medical records --Air sampling or other environmental monitoring results--Equipment and process testing, inspection, and maintenance --Respirator testing, training, and use--Noise exposure monitoring and hearing conservation program--Forklift evaluation and training--Hazard assessments for determining PPE needs
The financial impact potential can be quite high. Potential fines can reach up to $10,000 and even jail time especially if it is determined to be willful. How do you stay up to date with this list of records that must be maintained? First start clean – make sure that you have what you need. From there, there must be active involvement from all of management from the line supervisor through the Safety Manager or EHS Manager.
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SERVICES AVAILABLE
With this growth there has also been an expansion of services. The list below outlines many of these services. If you don’t see what you need on this list, call and talk to us and we will do our best to see to your compliance and safety needs.
* Food Security Plan Development
* HACCP Plan Reassessments * HACCP Plan Developments
* Workplace Safety – OSHA Compliance and Workman’s Comp Cost Reductions
* Food safety & Quality Audits * Sanitation / GMP Audits
* Audit Preparation – Silliker, Cook & Thurber, AIB * SPS / SSOP Separation Project
* IVT Preparation / Listeria Assessment * Quality Process Improvements
* Operations Management Improvements (TOPS) * HACCP Training Workshops
* Product Recall / Crisis Management Planning * Food Security Plans
* Manpower Reductions / Efficiency Improvements * Waste Water Control / Cost Reductions
* Animal Welfare Audits * Small Plant Layout and Design
* Training Seminars – Food Safety, Regulatory, Quality Topics
* Regulatory Compliance – EIAO Prep Audit or NOIE Response
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OSHA News
1. NFPA Fact of the Week - brought to us by the NFPA - NFPA Report: cooking is #1 cause of home fires. Cooking was involved in 146,400 home structure fires in 2005, causing 480 deaths and $876 million in property damage. Get the report, read safety tips, and listen to audio on this topic. http://www.nfpa.org/newsReleaseDetails.asp?categoryID=488&itemID=38266
2. OSHA Confirms the Effective Date of the Direct Final Rule to Update its Standards Based on National Consensus Standards http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=NEWS_RELEASES&p_id=15040
3. OSHA Notifies Workplaces with High Injury and Illness Rates http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=NEWS_RELEASES&p_id=14999
OSHA Enforcement
Dairy worker severed fingers in accident { http://m1e.net/c?73693935-/Q1GEKvjxHlHM%403196443-2OXZgF9Nqck.6 }Interlocks Overridden on Guard!!! - (a dairy firm has been fined thousands of pounds after a worker severed the tops of three of her fingers in an accident at its plant - a female employee was changing machinery that puts labels around plastic milk bottles when automatic guards which prevent access to the machine's cutting blades were manually over-ridden - the tops of three of the woman's fingers were severed - it is not known how the guards had been manually over-ridden)
Cheese plant evacuated after acid use { http://m1e.net/c?73693935-VTQgWjfT6ija.%403196464-M5.aPs6exugL6 } (a cheese plant was evacuated and emergency crews called after an employee accidentally used nitric acid during a sterilization process instead of a caustic solution - the incident — which did not result in any injuries — occurred about 10 p.m. - workers immediately started flushing and ventilating the area and evacuated the building)
Employer liable for injured worker’s` subsequent suicide { http://m1e.net/c?73693935-uxZ4E5kHCclMA%403203898-wbm5RCmNdIrUI } (companies will have to take action to look after the mental health of workers who suffer a physical accident at work, following a landmark ruling on employers’ liability in suicide cases)
Imperial Sugar Worker Files Lawsuit Against Contractor { http://m1e.net/c?73693935-Xikj5WuvXRXJE%403203912-kESJFYbvsY4Hk } (six weeks after the sugar refinery explosion, a lawsuit has been filed - employee has filed a lawsuit against a longtime contractor at the sugar refinery tasked with cleaning the plant, among other things - she used to work for the contracting company until being hired by the refinery a few months ago - she had worked inside the pant for a year - she suffered burns on her arms and goes for treatment every week)
No injuries reported in dust explosion at Quaker Oats { http://m1e.net/c?73693935-SUHr7nv7seDKE%403203913-CK7dMyF8Th0M6 } (fire crews were called to the plant after a dust explosion on the eighth floor of what is called the "B House" - crews arrived about 7:15 a.m. and found lots of smoke but no flames - no injuries have been reported and workers are not being kept away from the building - crews are making sure augers didn't carry any embers to places they haven't checked)
Global Egg Corporation fined $50,000 for a health and safety violation { http://m1e.net/c?73693935-UUoqIW0VgFMPI%403228180-4cwrkMcRlFLA } GUARD IT!!! (worker was under a loading machine setting up the drip sanitizer tray while the machine was running - the machine's drive shaft was covered by an "L" shaped metal cover, which was not bolted in place or interlocked to the machine motion - the cover fell to the floor when the worker knocked it - the worker's hairnet and hair became entangled in the rotating shaft, causing scalp injuries - a Ministry of Labor investigation found that the rotating shaft was inadequately guarded and there was access to moving and rotating parts)
EPA News & Enforcement
Rain Caused Waste to Ignite http://enviro.blr.com/display.cfm/id/87830 - A company that makes food supplements for the dairy industry agreed to pay $70,000 for alleged violations of federal hazardous waste regulations, reported the Arizona DEQ. - As alleged by DEQ, inspections of the Eloy-based company uncovered a ton of calcium oxide stored in a Dumpster, where it was exposed to rain three times in 2005. When exposed to water, calcium oxide undergoes a chemical reaction that releases heat. - DEQ inspected the site 2 days later, but two more fires occurred the following month before the company took steps to store the calcium oxide in a safe, dry place. The company mixes the calcium oxide with palm oil to produce cattle feed.
DHS
Clears Up Propane Confusion - Since the publication of the
Appendix A list of Chemicals of Interest, the Department of Homeland
Security (DHS) has received numerous questions about the screening threshold
quantity for propane and the applicability of the release-flammable mixture
provisions of the Chemical Facility Anti-Terrorism Standards to products
that contain propane.
http://tr.subscribermail.com/cc.cfm?sendto=http%3A%2F%2Fenviro%2Eblr%2Ecom%2Fdisplay%2Ecfm%2Fid%2F87453&tempid=1c1619985d9e4381bca6f53c33025f7a&mailid=316003db5b614f5abe25e91381d66a85
3.
Most Voluntarily Disclose Environmental Violations -
If you voluntarily disclose your environmental violations, you may be
able to reduce up to 100 percent of your gravity-based penalty under the
incentives of the federal Self Disclosure and Environmental Audit Policy. In a
recent Enviro.BLR.com poll, we asked our readers if they voluntarily
disclosed violations.
http://tr.subscribermail.com/cc.cfm?sendto=http%3A%2F%2Fenviro%2Eblr%2Ecom%2Fdisplay%2Ecfm%2Fid%2F87117&tempid=7fb58cec92384428b067f53c33025f7a&mailid=316003db5b614f5abe25e91381d66a85
Poultry Litter May Be Turned Into Energy in the Future - The Chesapeake Bay Program Office has completed a report {http://www.chesapeakebay.net/content/publications/cbp_17018.pdf} stating that poultry litter may someday be converted into an energy source. The report explores the technologies that may someday make this feasible and identifies the roadblocks and incentives that a litter-to-energy project may encounter. If feasible, the amount of poultry manure that makes its way into the Chesapeake Bay Watershed could be substantially reduced.
Study: People Rank Global Warming Lower than Water, Smog - http://www.1105newsletters.com/t.do?id=1062695:&recipid; Results from a survey conducted by a University of Missouri professor reveal that the U.S. public, while aware of the deteriorating global environment, is concerned predominantly with local and national environmental issues...
EPA Fines Deli Meat Manufacturer $36,400 for Ammonia Release Reporting Violation - EPA recently fined the Bridgford Foods Corporation $36,400 for a 2006 ammonia air release violation at its food packaging plant located in Anaheim, Calif. - Bridgford Foods did not properly notify the National Response Center, the California Office of Emergency Services, or the Anaheim Fire Department, which was a responder to the emergency incident. - According to the EPA, in June 2006, Bridgford Foods Corporation released more than 4,000 pounds of ammonia due to equipment strainer failure. This release was a reportable quantity under the federal Emergency Planning and Community Right-To-Know-Act (EPCRA or SARA Title III) as well as under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). Under the regulatory requirements, ammonia has an established 100-pound reportable quantity.
Quality (ISO) Information
1. Finding the Right Calibration Software by Steve Wichelecki. - Regardless of size, facilities with the need to calibrate instruments can benefit from the implementation of calibration software. Such software allows an organization to keep all calibration records, calibration procedures and requirements, instrument location and instrument history records in a secure, readily accessible database. http://click.bnpmedia-email.com/?ju=fe2715777c670c7f771577&ls=fdea1679776107747d16747c&m=fefb1670746d0c&l=fec312707d660378&s=fdf915707661027f7d147672&jb=ffcf14&t=
ISO launches project committee to develop international standard for energy management http://www.iso.org/iso/pressrelease.htm?refid=Ref1122
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CHILTON CONSULTING GROUP – PERSONAL PROFILES
In each issue a different person will hold the top spot in an effort to make everyone aware of the diverse nature of this group and the wide range of services and expertise that we have to offer. I have included everyone’s email address so that if you have questions you can go directly to the person of interest.
Dr. Estes Reynolds agfood@charter.net
1) HACCP Training
2) HACCP Plan Reassessments
3) Microbiological issues,
4) Pathogen trouble shooting,
5) Process improvements.
6) Quality improvements,
7) Plant Layout and Design for Small Processors.
Sharon Chilton schilton@alltel.net
1) Maintains the corporate library, assist with accounting and marketing details and coordinate consulting projects.
Jeff Chilton chilton@alltel.net
1) HACCP Plan Reassessments
2) Regulatory Responses to NOIE or Notice of Suspensions
3) IVT/Rlm Audits
4) Audit Preparations Services / Food Safety and Quality Audits
5) HACCP Training
6) Quality Improvements
7) TOPS: Total Operational Performance System
Dr. Ron Beckman drbeckman@tampabay.rr.com
1) Slaughter, slaughter regulations and improvements to the slaughter process.
2) USDA compliance assistance and mediation,
3) HACCP Plan reassessments,
4) Animal Welfare Audits,
5) HIMP Implementation projects,
6) BEV/Beef export Programs and
7) General productivity and efficiency reassessments.
Bobby Pace bobbypace@knology.net
1) HACCP and Food Safety Consultant
2) HACCP Plan Reassessments
3) Quality Improvements
4) ISO Implementation / Auditing
David Rowe safety01@hughes.net
1) Facility Safety Training
2) Mock OSHA Inspections, Safety Audits
3) Mechanical Integrity Tracking
4) HACCP Plan Reassessments
5) ISO Implementation / Auditing
6) Website / newsletter development
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Chilton Consulting Group will provide affordable expertise in the areas of regulatory compliance. The cost of non-compliance can be enormous. Keeping compliance issues in-house can cause deficiencies to be overlooked. We will work with Your company to ensure compliance and reduce employee injury and exposure. In doing so, you will save money with fewer (or no) citations, decreased liability, and reduced insurance costs as well as fewer lost time accidents. We offer your Company our expertise in matters regarding OSHA, EPA, ISO and USDA compliance as well as a wide variety of compliance related activities. The following list outlines the areas in which we can help.
OSHA:
Safety Plan development or modification.
Mock OSHA Audits to evaluate your level of compliance.
Safety training for many different topics. – Email us with your
needs.
Process Safety Management (PSM) Needs: Audits, PHAs, Training,
Development or Modifications
OSHA Requires Safety Plans (manuals, documentation). We are
able to develop these for you or modify your existing ones to ensure they are
complaint without being burdensome.
EPA:
Good Laboratory Practices (GLP) Audits, Plan development or
modifications
Risk Management Plan (RMP) Compliance Audits
ISO:
Plan development or modification.
Third party audits to ensure compliance
Please feel free to call us with any questions, concerns or to schedule a meeting or training class.