What should NOT be included in the Benicia Industrial Safety Ordinance and why?

The facility should have the final say on facility operation based on their hazard analysis results. The local agency known as CUPA does have the oversite, and do conduct routine inspections that covers the hazardous materials plan, and hazardous waste management plus underground tanks if applicable. This agency (Solano County Department of Health Hazardous Materials Division) do have the oversite, and they or their representatives (consultants) do review their CalARP written program, and work with the facility during their hazards analysis efforts. Each facility has a technical staff that maintains the process safety information, mechanical integrity program, operating instructions known as operating procedures, evaluating changes to the affected process known as management of change, and other safety management systems plus review the air dispersion models generated from worst credible release scenarios. Using outside experts create an unnecessary layer that could create undue burden to confusion. Management of change is a management system, where the facility conducts a safety assessment for each change to the process such as process set points, material of construction, and control system for the process strategy changes. This management of change process is a team base, where the process change owner is required to seek input from the affected groups such as operations, maintenance, technology, and other departments within the facility to ensure the potential of a safety impact to the employees, and material releases are minimized.

The ISO should be flexible and able to change with the times. It should not specify equipment or particular methods of doing things that could be improved over time. While it is important that major industries have a part in developing an ordinance it is important that they do not have the final say. It should be developed by independent experts.