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Little General Store Propane Explosion - US Chemical Safety and ...

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<strong>Little</strong> <strong>General</strong> <strong>Store</strong> September 2008<br />

would not have detected the improper installation at <strong>Little</strong> <strong>General</strong>. Ferrellgas’ instructions on<br />

conducting audits merely recommend SCGMs inspect customer installations that were filled on the day<br />

prior to the review or inspect those that the manager is driving past. These methods of sampling provide<br />

no way to systematically review all installations over time.<br />

SCGMs’ <strong>and</strong> regional technical analysts’ audits focus primarily on identifying <strong>and</strong> correcting deficiencies<br />

at facilities <strong>and</strong> customer locations. Only those installations that are spot-checked during the quality<br />

review are corrected; therefore broader systemic problems may remain undetected. In contrast, generally<br />

recognized <strong>and</strong> accepted practices for auditing safety management systems focus on assessing <strong>and</strong><br />

verifying system effectiveness. 37 These practices include using statistical sampling, trend analysis,<br />

management system review, <strong>and</strong> corrective action to detect systemic problems <strong>and</strong> ensure ongoing hazard<br />

control throughout the organization. 38<br />

5.3 <strong>Propane</strong> Service Technician Training <strong>and</strong> Response<br />

5.3.1 <strong>Propane</strong> Service Technician Training<br />

5.3.1.1 Federal <strong>and</strong> State Training Requirements<br />

The United States Department of Transportation (DOT) <strong>and</strong> OSHA regulations have limited propane<br />

service technician training requirements. DOT requires training only for propane personnel who engage<br />

in transportation activities. OSHA requires training for propane service technicians but does not elaborate<br />

on this requirement (Section 6.1).<br />

37<br />

St<strong>and</strong>ard safety texts describe audits as systematic, independent reviews that determine conformance to company<br />

<strong>and</strong> industry st<strong>and</strong>ards whereas inspections are physical inspection of installations <strong>and</strong> facilities.<br />

38<br />

CCPS, 1993; Petersen, D., 1996; Weinstein, M.B., 1997<br />

36

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