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Compliance Support

Maximize Lethality Minimize Risk.  The ethos that drives TCI daily to ensure the ammunition and explosives industry is efficient, safe, and most effective at producing the munitions required by our sons and daughters as they protect this Nation!  TCI is uniquely postured to leverage our experience from all three sides of the Maximum Lethality Triad (Military, AE Industry, and Regulatory) to assist your organization through the complexities of DoD Manual 4145.26 compliance through site feasibility assessments, virtual program reviews, process risk management, and/or process hazards analysis.  Allow TCI to guide your organization through a structured, efficient process to your desired end state.

TCI's Capabilities:

Navigating the complexities of regulatory compliance is challenging!  Our personnel have been in your shoes.  We have the experience required to design an efficient path for your compliance team. Below are some of the "Hot Button" issues where the TCI Team excel:

Subcontractor flow-down compliance

Most US Government A&E procurement contracts will contain a reference to DFARS 252.223-7002, Safety Precautions for Ammunition and Explosives. This DFARS clause holds the prime contractor responsible to ensure all sub-contractors are also in compliance with the 7002.

Comprehensive explosives safety programs

Contractors shall examine all aspects of an AE operation and shall determine a safe and orderly course of action for accomplishing the work (DoD Manual 4145.26, C3.3.1). Contractors are required to have a complete and inclusive AE Safety Program compliant with the DoD regulations as well as a robust Process Safety Management program IAW 29 CFR 1910.119.  Our personnel are well versed in lockout/tag out, confined space entry, PPE, hazards assessments, electrical requirements and other elements that comprise a comprehensive explosives safety program.

Explosives safety site plan (ESSP)

A key component and central to the Explosives Safety Program is the ESSP.  This document articulates required safe operational and storage distances and highlights the organization’s safety program by identifying end products, raw material inputs, handling procedures (pre-, during, and post-processing), references to SOPs and PHAs, critical infrastructure, inclement weather procedures, emergency response procedures, etc.  Additionally, ESSP is another tool to evaluate and ensure the safest possible work environment for your personnel and community.  This document is critical to your Explosives Safety Program compliance as stated in the DoD Manual 4145.26

Quantity distance analysis

Part of the contractor's Explosives Safety Site Plan is an analysis of all energetic material, their hazard divisions, and net explosives weights to ensure operational, storage, and unrelated-facilities have the proper stand off to protect from overpressure and fragmentation in the case of an unintended initiation. Secondarily, it is imperative to consider the storage of unlike energetic materials and separation required to defeat sympathetic propagation.

Site feasibility assessments

Determining if a site is compatible with AE production process is a daunting task and often leads to paralysis by analysis.  We've designed a simple process that can be accomplished (in most cases) in a one-day site visit with input from your key process owners.  

Process Hazards Analysis

Process Hazards Analysis is foundational to ensure the organization designs safety into the development of standard operating procedures. PHAs are NOT a safety team product.  An experienced team leader must ensure management, production, engineers, facility maintenance, and safety are all involved to identify inherent risks (DoD Manual 4145.26, C11.2)

CAR analysis and response development

Despite even our best efforts, this is a high-risk production environment and industry.  Whether it is through oversight or complacency, deficiencies will happen. The Regulatory leg of our Maximum Lethality Triad is the safety overwatch providing a third-party set of eyes. When necessary, a corrective action request (CAR) can be issued to refocus an organization.  TCI is postured to analyze deficiencies, design/improve processes, and assist with CAR responses to regulatory agencies.

Blast analysis and modeling

Maximize  distance, minimize exposure, and minimize weight!  A paraphrased core principle to ammunition and explosives safety. On legacy plants or areas with encroachment, we might not be able to maximize distance. The 4145.26 and DDESB allows use of the Unified Facilities Code to design blast mitigation into facility construction. Our engineers use the DDESB-recognized SHOCK and FRANG codes to model the overpressure and reflective shock wave produced by an unintended initiation of your energetic material.

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