‘Vision + Patience’
NFPA’s Certified Fire Inspector training helps Dow Corning earn high safety marks from its insurer
NFPA Journal®, March/April 2011
By Alan Earls
How good is good enough? That was one of the questions Mike Snyder faced in 1990 when he first arrived at Dow Corning Corporation in Midland, Michigan, the company’s flagship facility and its largest manufacturing plant. Dow Corning is an equally owned joint venture of Dow Chemical and Corning.
How, and How Often?
Fire pumps are a critical component of built-in fire protection systems, and to ensure reliability, they must be tested periodically.
NFPA’s Certified Fire Inspector Program
The NFPA Fire Inspector I and II certification programs were developed in response to requests to develop certifications founded on the NFPA professional qualification standards and other applicable NFPA codes and standards.
At the time, Dow Corning’s safety and loss prevention program was good but, in Snyder’s view, could have been better. One element that concerned him was his staff. "It was obvious to me that we had the resources, but we weren’t stretching them and using them to our best advantage," says Snyder, currently the company’s global director of corporate safety, industrial hygiene, and loss prevention. He’s also an NFPA member who sits on the Standards Council.
Snyder wanted to redefine the mission for what his personnel did, and he wanted to enhance their skills and bring a new professionalism to how they did their jobs. "Security officers" became "loss prevention officers" (LPOs), and Snyder initiated new training designed to expand their responsibilities, including physical site security and managing risks involving fire, hazardous materials safety, and emergency medicine.
A key element of this transition, especially in recent years, has been the NFPA Certified Fire Inspector (CFI) program, which Snyder’s LPOs began taking in the early 2000s. To date, more than 20 LPOs — most of Snyder’s team — at the Midland plant and nearby facilities have obtained CFI designation, which was particularly useful in providing personnel with knowledge of NFPA 1, Fire Code; NFPA 13, Installation of Sprinkler Systems; NFPA 25, Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems; NFPA 72®, National Fire Alarm and Signaling Code; and NFPA 101®, Life Safety Code®.
Three additional members, including Snyder himself, have obtained Certified Fire Protection Specialist (CFPS) designation, which Snyder says has generally been reserved for senior technical loss prevention professionals or engineers who have extensive field experience. "Right now, all of our CFPS certificate holders, myself included, are either engineers or senior technical staff in the Safety and Loss Prevention Department," he says. "We find a similar value in the third-party credentialing through CFPS for our senior technical staff as we have found for CFI."
The extra attention to safety, including fixed fire protection, is paying off, starting with high marks from Dow Corning’s insurer, FM Global. Paul W. Higgins, assistant vice-president/senior account engineer for FM Global Chemical Operations, explains that his company uses an assessment method that divides risks into a handful of categories, including facilities hazards, equipment hazards, natural hazards, general occupancy issues, and a category designated "human element." According to Higgins, Dow Corning has implemented risk improvements in all five categories over the past five years, with particular attention to its human element programs, which focus on the processes, procedures, and capabilities that employees bring to bear on safety and loss prevention issues.
"Dow Corning’s scores have been improving by an average of about 10 percent per year," says Higgins. "These improvements have been especially challenging, since Dow Corning is part of the chemical industry, which is generally acknowledged as having significantly greater hazards than industry in general. Dow Corning management understands that human-element programs are core to ensuring the sustainability and effectiveness of all other risk-control measures, including physical protection systems like automatic sprinklers."
The challenge of infrastructure diversity
Snyder says there were several reasons to make the change. Dow Corning had embraced a series of safety and loss prevention improvements under the framework of the Responsible Care® Program, a global voluntary initiative launched by the chemical industry whereby companies, through their national associations, work together to improve their health, safety, and environmental performance. "It started to make sense to invest in broadening the skills of our loss prevention staff to support our improvements at the grassroots of our organization," says Snyder.
In addition, the regulatory environment in the early 1990s included OSHA HAZWOPER (Hazardous Waste Operations and Emergency Response Standard 1910.120), which provided more specific professional requirements for Snyder’s team to grow into. Finally, he says, the LPO program provided staff with many more avenues for professional growth and motivation, and new hires were expected to meet higher standards than in the past. The operating philosophy became "up or out," Snyder says, and it wasn’t without its casualties. "Most of the team was willing to take on more training and responsibility, but a few just couldn’t make the change," he says.
Snyder’s new team of trained LPOs set about monitoring physical protection systems such as sprinklers and alarms, work that included testing and maintaining the facility’s myriad protection systems and networks. They also began assisting with the preparation for any hot work, says Snyder, and as a result, fires due to hot work, a common problem in the chemical industry, are extremely rare at Dow Corning, he says. "We even have a former LPO who sits on the technical committee for NFPA 51B, Fire Prevention During Welding, Cutting, and Other Hot Work," Snyder says.
It’s the work on the physical protection systems that has proven most challenging, however, as well as most rewarding. Midland is a vast and complex maze of equipment and functions focused on all aspects of silicon and silicone chemistry. The facility covers more than 500 acres (202 hectares) and employs approximately 1,200 people who produce some 7,000 different products and services for global markets. About 10 percent of the buildings at Midland date back to the 1940s, Snyder says, and include mostly offices, workshops, and storage areas. A substantial number of buildings date from the 1950s through the 1970s. At the same time, he says, there has been significant investment recently in new structures and manufacturing equipment.
For Snyder and his loss-prevention team, this diversity in the plant’s infrastructure presents special challenges, including the need to maintain technical knowledge of the operating characteristics of equipment, including fire protection systems, that is older than many of the employees. "As part of our continuous process of manufacturing-process hazard reviews, we identify situations where original fire protection designs may need to be enhanced to meet the results of more modern fire protection research or the content of updated codes and standards," says Snyder. As systems age, the codes and standards require additional and more frequent testing protocols. When a sprinkler system reaches 50 years of age, for example, NFPA 25, Water-Based Fire Protection Systems, requires that sprinklers be replaced or a specific sampling and test regimen be used to ensure that the sprinklers are still operational, Snyder says.
Snyder and his teams appear to be mastering these special challenges. According to Higgins, Dow Corning’s overall score in the general chemical category is notably higher than the overall average for FM Global clients in this category. In the high-hazard group, Dow Corning’s score is also notably higher than the average score for the company’s other clients in this group. Despite the fact that the Midland facility is Dow Corning’s largest and oldest site, it boasts an overall score in the top quartile among similarly evaluated FM Global clients, which Snyder says has been a long-term goal of the company.
Dow Corning is being recognized by others, too. Last year, EHS Today, a magazine focusing on the management of risk in the workplace and environment, added Dow Corning to its list of America’s safest companies. The company also participates in the American Chemistry Council’s Responsible Care Program and has achieved a global environmental ISO14001 certification.
Engaging the LPOs
One of the people making all this happen is Doug Behmlander, a Dow Corning LPO and a graduate of NFPA’s CFI Program. Behmlander, 53, a 20-year veteran of the company, has held LPO positions at the company’s Midland plant and elsewhere. At first, he says, taking on the extra work involved in certification wasn’t something he was thrilled about. "I was at the Auburn (Michigan) site when the fire inspection program began, and, to be honest, I thought it was a pain," he admits. But the training program "opened my eyes," he says. Now he’s hooked, to the point where he’s become something of a code junkie. "It sounds geeky, but on slow days I’ll often sit down and just read through the codes," he says. "And then, days or maybe weeks later, I’ll spot something in a system that doesn’t match up with what the codes require." Behmlander says he then enters a work order into the system to make the needed changes or repairs.
Another LPO, Rick DeCaire, already had experience as a firefighter when he began the certification program. He says certification strengthened his skills, both on the job and as a volunteer firefighter in the community. It also opened professional doors. Today, DeCaire works as an environmental specialist at Dow Corning, which combines LPO training with the knowledge learned from becoming a fire inspector. The training also encouraged him to launch the Central Michigan Fire Inspectors, a professional association that provides continuing education opportunities for fire professionals. "What I learned as a CFI helped me develop as a volunteer firefighter in Auburn, where I’ve taken on a role in reviewing plans for proposed construction," he says.
Snyder has found that getting LPOs engaged and motivated pays off in many different ways. John McLaughlin, a senior LPO at Midland who has been with the company and working at the site since 1988, used his NFPA CFI training to initiate important changes in inspection practices. "When I started here, we all thought our inspection procedures were pretty good," he recalls. "For instance, every week we would go out and visit our riser locations — we called it our OS&Y valve route, as in ‘outside screw and yoke.’ " Inspections included checking water pressure and air pressure and making sure there was no evidence of tampering. "For a long time, no one challenged the value of the data or really stopped to think about our priorities related to those valves," he admits.
But exposure to NFPA training programs provided a new perspective. Armed with a broader definition of what to inspect, a four-member team organized by McLaughlin, three of whom were CFI-trained, went on what he calls a "search-and-destroy" mission to find anything that could interrupt the flow of water into or through the sprinkler system. "If we found a valve, we would identify why it was there, and if there was no good reason for why it was there we removed it," he says. The team discovered valves they had not been aware of, categorized them, and checked the codes for information on the required frequency of inspection. All the information was captured using computer software to ensure that proper testing and maintenance would occur regularly in the future.
Now, each valve is bar-coded, and inspections are conducted using a question set based on guidelines in NFPA 25. When alarm systems are involved, guidelines based on NFPA 72, National Fire Alarm and Signaling Code, are also referenced.
The enhanced testing has helped identify a number of valves, affecting 30 of the facility’s 70 deluge sprinkler systems that are 20 years old or older, that had begun to fail and could not be repaired due to lack of spare parts. "We were able to get support from management for capital funding to replace those outdated units," adds McLaughlin.
These days, Snyder has his sights set on a new goal: achieving "highly protected risk" (HPR) status. Snyder explains that HPR is a designation awarded by insurers indicating that an operation has a much lower than normal probability of loss by virtue of well-managed hazards, superior construction, special fire protection equipment and procedures, and management committed to loss prevention. "We think HPR designation is achievable by the end of this year," Snyder says.
For Snyder, the bottom line is if you don’t have accidents, you’ll be a more successful business. He notes Dow Corning’s continuing growth, including a $1.5 billion expansion of its facility in Hemlock, Michigan, and another $1 billion expansion in Clarksville, Tennessee. "We don’t necessarily have a single magic bullet — our business success is based in part on a foundation of safety and loss control," says Snyder. "What I’ve tried to bring to our programs is vision and patience."
Alan Earls writes on technical and safety topics and is based in Franklin, Massachusetts.
How, and How Often?
Dow Corning joins Research Foundation fire pump initiative
Fire pumps are a critical component of built-in fire protection systems, and to ensure reliability, they must be tested periodically. But how often to test the pumps and how to test them have remained topics of discussion. The dialogue continues more than a century after NFPA issued the first edition of NFPA 20, Installation of Stationary Pumps for Fire Protection, due in part to the fact that field data have never been collected in a comprehensive manner that could support statistical analysis and thereby clarify the value of a particular method, frequency, and observation of testing.
Now, a new project of the Fire Protection Research Foundation (FPRF), supported in part by Dow Corning, aims to gather credible and statistically valid fire pump performance data. Casey Grant, FPRF program director, says the project intends to collect existing fire pump performance data and examine previously questioned unforeseen failure sources. Eventually, he says, this could lead to the development of a standardized and statistically valid data collection framework for fire pumps and, in the future, other fire protection equipment.
Mike Snyder, director of corporate safety, industrial hygiene, and loss prevention at Dow Corning, notes that the frequency of fire pump testing is being actively debated and that Dow Corning wants to be part of the discussion. "Since our U.S.-based operations have dozens of fire pumps with numerous years of operating and maintenance history, we’re willing to share our experience and information to help reach the best guidance for future versions of the fire pump testing and maintenance documents," he says.
FPRF’s Grant says the project is scheduled to be completed by January 2012 and that a report would be available at that time. For updates, visit nfpa.org/foundation.
NFPA’s Certified Fire Inspector Program
The NFPA Fire Inspector I and II certification programs were developed in response to requests by fire inspectors, plan reviewers, state agencies, and national organizations to develop certifications founded on the NFPA professional qualification standards and other applicable NFPA codes and standards.
Laurent R. McDonald, manager of NFPA’s Certification Program, says that the purpose of the Certified Fire Inspector (CFI) Program is to prepare fire inspectors and others responsible for fire safety inspections or surveys for certification based on job performance requirements found in the 2009 edition of NFPA 1031, Professional Qualifications for Fire Inspector and Plan Examiner. The program offers courses through NFPA’s Professional Development Department and NFPA affiliates. The examinations ensure that participants have achieved minimum competencies around skills such as applying fire-related codes and standards, the duties of the authority having jurisdiction and the fire inspector, and the importance of code enforcement.
Bill Galloway, assistant state fire marshal for South Carolina, says his state adopted CFI as the recommended training program for all state, county, and municipal fire inspectors. In particular, he notes, CFI has a practicum requirement that other certification programs lack. “Candidates must complete seven supervised inspections within six months of completing the written exam,” he says.
Mike Snyder, global director of corporate safety, industrial hygiene and loss prevention at Dow Corning, says adopting CFI for his loss prevention officers (LPOs) provides third-party verification of specific work experience and demonstrated knowledge and capability. As a result, Snyder says his team can resolve more technical issues in these areas at the LPO level than ever before, meaning more rapid and focused turnaround for fixing problems. “In addition, our enhanced skill set is identifying more improvement opportunities earlier, which allows the problems to be addressed before they become issues,” Snyder says.
Program fees are $300 for the exam and an additional $90 if a candidate chooses to buy the reference set, which includes NFPA 1, Fire Code, 2009; NFPA 13, Installation of Sprinkler Systems, 2007; NFPA 25, Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, 2008; NFPA 72®, National Fire Alarm and Signaling Code, 2007; and NFPA 101®, Life Safety Code®, 2009. Purchase of IFSTA Fire Inspection and Code Enforcement, available from Fire Service Publications (www.ifsta.org), is also required.
For information about these certifications, visit nfpa.org/certification, email firstname.lastname@example.org, or call 617-984-7432.