Document KGEgeeNJrK75aNrL9YEkRZKp2

||^rM i r*rn i r rs To: I. Klimas INTER-OFFICE CORRESPONDENCE Date: January 30, 1978 From: z. G. Bell, Jr. Location: 1 0 West Subject:Workpractice^ Mr. K. Lynch Comments I responded to you concerning Mr. R. Lynch's comments on the implementation of The Chemical's Group VDCM Workpractices at Lake Charles. When Phil Snyder and I were in Lake Charles in October, Phil went through the VDCM area to audit the compliance with these new workpractices. The deficiencies Phil noted were discussed briefly with Mr. J. Farst upon our exit interview. As background information, when we review a program at the plant we think we do a thorough evaluation and not superficial. In addition to a review of the workpractice, item by item, we do a walk through to observe that what has been told us by management is being followed in the work area. Any descrepancies are noted. We also talk to the foreman and workers to ascertain their understanding of the required procedures. Often there are differences noted, misunderstandings, misinterpretations and in some instances total unawareness that a workpractice exists. I do not mean to imply that the plant has not or is not taking action to implement the workpractices as reported by Mr. Lynch. The descrepancies we note are those seen on our visit which may be present only during our review, however, some are of such a nature that one is lead to believe they will continue to persist beyond our visit. I believe it is our responsibility to highlight our observations and discuss these with plant management to get them resolved and to keep Pittsburgh management advised of our findings and the plant's progress. ZB/mec cc: ^f. c. Dehn H. C.'Twiehaus P. J. Snyder W. R. Harris received jAN U 1978 Environmental Affairs' FOAM 903.A REV. 0-1-7O