Document 9JvVBq1e8j3kgL7QZx4k8XgQ3

DOW LOUISIANA DIVISION CONSOLIDATED AUDIT J. J. MULLER MAY 29,1991 DO A 023426 CONFIDENTIAL 0 00 0000.000 000 . : , ' 0*. -/O' A" -OO--; r: r-_ OOOOOQD 0:0.0 Q O 0 O 05/91 DO A 023427 CONFIDENTIAL Core Audit Team NOTE: Core Aduit Team will attend entire audit (3 days). DO A 023429 CONFIDENTIAL Functional Audit Team/Leaders Safety Don Jones Chemical Exposure Index Jim Gibson (CEI) Hazardous Materials Transportation (HMTI) Dean Smith Occupational Health Gary Meier Geof Kusch Reactive Chemicals Gerald Wagener Loss Prevention Buck Bailey Security A1 Lott Other Audits * Electrical * Burner Management Charlie Peters DO A 023430 CONFIDENTIAL AUDIT PROCESS BEFORE/AFTER AUDIT 1. Send questionnaires to Plant Superintendent for distribution to plant team. 2-3 months before 2. Plant team member contacts professional counterpart to help fill out questionnaire, identify needs, and propose corrective action. 3. LAD audit facilitator has pre-audit conference with Plant Superintendent and plant team. 1 month before 4. Any ''other" audits/inspections completed. 2-3 weeks before 5. Questionnaires returned to LAD audit facilitator and then distributed to functional audit team leader. 10 days before DO A CNFxo 023431 Eh>T I At. AUDIT PROCESS BEFORE/AFTER AUDIT 6. Three day audit. (Tue, Wed, Thu) 7. LAD audit facilitator coordinates recommendations into one report for the plant. 2 weeks after 8. Plant reviews report/actions with Maior Manager (-> General Manager; and replies to core audit team with implementation plans. 45 days after 9. Plant issues follow up status report. 6 months after 10. In keeping with OSHA Star, plant issues final status report. 1 year after 11. Technology Center conducts technology review. 1 year after D0 A 023432 CONFIDENTIAL LOUISIANA DIVISION CONSOLIDATED AUDIT TIME: 7:30 a.m. - 4:00 p.m. CONSOLIDATED AUDIT AGENDA (Proposed Agenda) Tuesday 7:30 - 11:30 11:30 - 12:00 12:00 - 1:30 1:30 - 1:45 1:45 - 4:00 Wednesday 8:00 - 8:30 8:30 - 11:30 11:30 - 12:00 12:00 - 4:00 Plant Presentation and Tour (see separate detailed guideline) Lunch Hazardous Material Transportation Review (HMTR) Break Chemical Exposure Index (CEI) Electrical Audit Reactive Chemical Review Lunch Occupational Health Audit DO A 023433 CONFIDENTIAL Thursday. 7:30 - 11:30 11:30 - 12:00 12:00 - 3:00 3:00 - 4:00 Safety Audit Lunch Loss Prevention/Fire/Security Audit Other Audits DO A 023434 confidential LAD CONSOLIDATED AUDIT Tuesday, 7:30 - 11:30 AGENDA (Proposed) Plant Presentation/Discussion/Tour I. Process and Unit Operations 90 minutes Process Description Process Flow Sheets Process Chemistry Including Side Reactions Instrumentation Critical Instrument Devices and Function Plot Plan Layout II. Organization 10 minutes III. Review of Plant/Department Policies/ Procedures and Communications 20 minutes IV. Review of Training and Retraining Programs 30 minutes Do A coNrro 23435 ntial V. Review of Significant Incidents/ Major Concerns Losses Reactive Chemicals Safety Medical VI. Plant General Tour (break into functional groups) Projects Areas of Concern Maintenance Shops Motor Control Centers Eating Facilities Labs HW:cmk 06-07-91 30 minutes 60 minutes D0 A 023436 CONFIDENTIAL LOUISIANA DIVISION CONSOLIDATED AUDIT PROGRAM SCHEDULE 1991 Slalus Completed Poly "A" Plant (Poly A Working On Action Plans) Robbie Stevens Scheduled Chlorine Plant Joe Muller Scheduled Vinyl II Chris Messelt Scheduled Power 1/Utilites Ken Fox Scheduled Glycol I Jim Henry Scheduled Caustic Carl Mercer To be scheduled Cell Service Roddey Peebles To be scheduled Vector SBC Max Williams May 28, 29, 30 July 29, 30, 31 September 10, 11, 12 October IS, 16, 17 November 5, 6, 7 November 19, 20, 21 1st Quarter, 1992 1st Quarter, 1992 HW:cmk 06/91 DO A 023437 CONFIDENTIAL CONSOLIDATED AUDIT GUIDELINE SUPERINTENDENT/DEPARTMENT HEAD ROLE THE SUPERINTENDENT/DEPARTMENT HEAD IS RESPONSIBLE TO ORGANIZE AND LEAD THE AUDIT FOR HIS/HER PLANT. HE/SHE IS RESPONSIBLE TO WORKOUT A SWAP IF THERE IS AN UNAVOIDABLE CONFLICT AND INFORM THE LAD AUDIT GROUP. 1. RECEIVES THE AUDIT PACKAGE FROM THE LOUISIANA DIVISION AUDIT GROUP 2-3 MONTHS BEFORE THE AUDIT DATE. 2. CONFIRMS THE AUDIT DATE AND NOTIFIES THE MAJOR MANAGER, TECH CENTER, AND SAFETY SUPERINTENDENTS OF THE DATES FOR THE AUDIT. 3. GETS HIS/HER PLANT TEAM ORGANIZED, REVIEWS THE PREVIOUS CONSOLIDATED AUDIT, DELEGATES THE AUDIT QUESTIONNAIRES, AND GIVES INSTRUCTIONS AND TIME TABLES FOR PREPARATION. 4. SOME SPECIFIC AUDIT PREPARATION REQUIREMENTS FOR THE PLANT SUPERINTENDENT ARE: A. ARRANGE FOR THE MAJOR MANAGER (OR SECTION MANAGER), A PROCESS ENGINEERING REPRESENTATIVE AND A SUPERINTENpENT FROM ANOTHER DEPARTMENT TO SERVE ON THE C.E.I. AUDIT TEAM. B. WORK WITH THE LOUISIANA DIVISION SAFETY MANAGER TO DEVELOP A PRACTICAL EXERCISE TO BE USED IN THE C.E.I. AUDIT. C. IF THE C.E.I. FOR ANY OF THE CHEMICALS IN THE PLANT IS GREATER THAN 300, THE U.S. AREA LOSS PREVENTION MUST BE INVITED TO THE AUDIT. D. IF THE HMTI FOR ANY OF THE CHEMICALS IN THE PLANT IS GREATER THAN 3, THE U.S. AREA LOSS PREVENTION MUST BE INVITED TO THE AUDIT. E. SAFETY MINIMUM REQUIREMENTS: ARRANGE WITH YOUR SAFETY SUPERINTENDENT TO DO (1) THE EMPLOYEE INTERVIEWS, (2) THE DOCUMENT INSPECTION AND (3) THE PHYSICAL INSPECTION OF YOUR PLANT AT LEAST 2-3 WEEKS BEFORE THE SCHEDULED AUDIT TIME. F. ANY OTHER APPLICABLE AUDITS AND INSPECTION MUST ALSO BE SCHEDULED 2-3 WEEKS BEFORE THE CONSOLIDATED AUDIT SO THEY CAN BE REPORTED DURING THE SCHEDULED AUDIT TIME. 5/20/91 DO A 023438 CONFIDENTIAL CONSOLIDATED AUDIT GUIDELINE SUPERINTENDENT/DEPARTMENT HEAD ROLE 5. SCHEDULE AND CONDUCT A PRE-AUDIT MEETING WITH THE LOUISIANA DIVISION AUDIT FACILITATOR ASSIGNED TO YOUR AUDIT. THE ENTIRE PLANT TEAM THAT IS PREPARING FOR THE AUDIT SHOULD ATTEND. THIS MEETING SHOULD OCCUR ABOUT 4 WEEKS BEFORE THE AUDIT. 6. THE LOUISIANA DIVISION AUDIT FACILITATOR AND THE SUPERINTENDENT/DEPARTMENT HEAD MUTUALLY AGREE UPON AND SET THE AGENDA AND SCHEDULE FOR THE CONSOLIDATED AUDIT. 7. THE PLANT TEAM AGREES ON THE AREAS OF DEFICIENCY AND CONCERN IDENTIFIED DURING THE QUESTIONNAIRE PREPARATION AND PREPARES "PRELIMINARY" RECOMMENDATIONS AND IMPLEMENTATION PLANS. 8. ASSIGNMENTS FOR PRESENTATION DURING AUDIT WEEK ARE MADE. THESE SHOULD ADDRESS THE TOPICS ON THE QUESTIONNAIRES ON AN EXCEPTION BASIS. SUGGESTED AGENDAS ARE INCLUDED IN MOST OF THE AUDIT QUESTIONNAIRES. 9. THE COMPLETED QUESTIONNAIRES, ALONG WITH "PRELIMINARY" RECOMMENDATIONS, ARE SENT TO THE AUDIT FACILITATOR AT LEAST 10 CALENDAR DAYS BEFORE THE AUDIT. INCLUDE LOCATION AND TIME FOR EACH AUDIT WITH THE QUESTIONNAIRES. 10. THE SUPERINTENDENT/DEPARTMENT HEAD AND KEY MEMBERS OF HIS PLANT TEAM WILL ATTEND THE ENTIRE AUDIT. SUPERINTENDENT/DEPARTMENT HEAD ATTENDANCE IS MANDATORY. 11. THE TEAM CONCEPT IS ALSO USED TO PREPARE THE IMPLEMENTATION PLANS IN RESPONSE TO THE CONSOLIDATED AUDIT RECOMMENDATIONS WITHIN 30 DAYS OF THE AUDIT. 12. THE SUPERINTENDENT/DEPARTMENT HEAD WILL REVIEW THE IMPLEMENTATION PLANS WITH HIS/HER MAJOR MANAGER (OR SECTION MANAGER). THE MAJOR MANAGER (OR SECTION MANAGER) WILL APPROVE THE RESPONSE AND COMMUNICATE THE RESULTS OF THE AUDIT TO THE DIVISION GENERAL MANAGER. 13. A COPY OF THE APPROVED IMPLEMENTATION PLANS WILL BE SENT TO AUDIT FACILITATOR WITHIN 45 DAYS OF THE AUDIT FOR DISTRIBUTION TO THE OTHER CORE AUDIT TEAM AND THE APPROPRIATE SECTION TO THE FUNCTIONAL AUDIT TEAM LEADER. 5/20/91 DO A 023439 CONFIDENTIAL CONSOLIDATED AUDIT GUIDELINE SUPERINTENDENT/DEPARTMENT HEAD ROLE 14. IN KEEPING WITH THE OSHA STAR PROGRAM, SIX MONTHS AND AGAIN AFTER ONE YEAR FOLLOWING THE AUDIT, THE SUPERINTENDENT/DEPARTMENT HEAD WILL REVIEW THE CONSOLIDATED AUDIT RECOMMENDATIONS AND SEND A STATUS REPORT ON CORRECTIVE ACTIONS TO HIS/HER MAJOR MANAGER, TO SECTION MANAGER, AND TO THE AUDIT FACILITATOR FOR DISTRIBUTION TO THE OTHER CORE AUDIT TEAM MEMBER AND THE APPROPRIATE SECTION TO THE FUNCTIONAL AUDIT TEAM LEADER. 5/20/91 D0 A 023440 CONFIDENTIAL