Document NENdX8G4DVreqqYZ8wXYnOewV

LOSS PREVENTION AUDIT Page 49 Management of Process Change/Project Reviews MANAGEMENT OF CHANGE REFERENCES: U.S. Area Standard No. 2, OSHA 1910.119 (1) A 1. Yes [X] No Does your plant's program for Management of Change include a written procedure which complies with Dow's U.S. Area Standard No. 2? See Attachment. A 2. When was your last audit for compliance with the Management of Change Standard? (Date) 10-20-94. Yes [X] No Have all recommendations from your last audit been closed? Please furnish documentation of your last audit findings. B 3. What is the involvement of your operation and maintenance personnel in the Management of Change process? They have been trained and are part of the CA II plant checklist. A 4. Please provide documentation of several completed checklists used for process changes during the pre-audit. A 5. Yes [X] No Are all employees, Dow as well as contractor, informed of and trained for process changes that affect them prior to the initiation of the change? How? Formal training sessions, tailgates, safety meetings, and communique book and yellow notes. (Revised 02/18/94; cmk) 3/28/95; LADibwb DO O LOSS PREVENTION AUDIT Page 50 _______ Management of Process Change/Project Reviews PROJECT REVIEWS REFERENCES: Minimum Requirements, U.S. Area Standard No. 2 A 1. Yes [X] No 0 Does your department have Engineering Project Reviews or other Project Review Processes? Who is involved? Project team members, operations, maintenance, safety, environmental, etc... B 2. Describe your process for handling recommendations from the project reviews. No formal process - have meeting with Engineering, operations plant staff, etc, discuss recommendations and change as needed. Please furnish documentation for the follow-up from these recommendations. B 3. Describe how new projects are integrated into the plant's operating discipline. Training, tailgates, updating plant resources, new/modified procedures. P&ID updates, control programs, operating discipline updates. (Revised 02/18/94; cmk) 3/28/95; LAD.-bwb DO A 047P71 OONFTDFNTIA1 LOSS PREVENTION AUDIT Page 51______________ _______ E. Pre-Startup Safety Review REFERENCES: Site Specific Standards, Dow Minimum Requirements, June 1989, OSHA 1910.119 (i) A l. Yes [X] No Do you have a Pre-startup Safety Review for all new facilities or changes to existing facilities? Plans: Safety & Loss Prevention Standard C-6. A 2. Do the pre-startup reviews address the following: a. Yes [X] Plans: No 0 Construction and equipment in accordance with design specifications? \ b. Yes [X] No Safety, operating, maintenance and emergency procedures are in place and are adequate? Plans: ________________________ Yes [X] No 0 Have the recommendations from the project review process been completed or considered? Plans: _______________ Yes Q No [X] Recommendations from the plant Process Hazard Analysis have been resolved and implemented prior to startup? Plans: No HAZOP reviews Please provide documentation for 2.a.b.c.d. [18/94; cmk) :bwb DO A 047??; CONFTDFNT T Ai LOSS PREVENTION AUDIT Page 52 ___________________ A 3. Yes [X] No Q Do you verify that training for all employees involved in operating the process has been completed prior to startup? Plans:___________________________________________ _________ ______ Please provide documentation. (Revised 02/18/94; crak) 3/28/95; LAD:bwb DO A 047003 c oNrinrNTTAi CHLOR-ALKALJII MANAGEMENT OF CHANGE NOTIFICATION OF PROCESS CHANGE CHECKLIST iype: LEVEL 1 (minor) O LEVEL 2 (moderate) O LEVEL 3 (major) Originator:Date of Origination:_________________ Proposed Date of Change: Area: PERMANENT TEMPORARY From:To: Description and Location of Change (Scope): Technical Basis for Change: Impact on: G Safety Type of Change: G Alarm G Shutdown Point Q Instrument G Loss Prevention G Environment GHealth GQuality OotherT G Process Computer Control G Addition/Removal of Equip. G Piping Modification O Equip./Material Modification G Chemical Addition Q Job Procedure RL #_______ G Process Setpoint Change G Product Specification Change Q Other________________ Applicable N/A Initials Pre-Modification Checklist: G Applicable N/A Consult piping and equipment specifications. G Applicable Gn/A Perform Reactive Chemicals testing. O Yes Q No In Process? O Yes No G Applicable Gn/a Add materials involved to Toxic Substance Control Act (TSCA) inventory. G Applicable N/A Calculate impact on F&EI and CEI. G Applicable G N/A Comply with Engineering Practices. G Applicable Gn/a Comply with Technology Center guidelines. i Applicable Gn/a Comply with Dow 'Environmental Protection Guideline for Operations". G Applicable Gn/a Comply with Safety & Loss Prevention and block requirements. G Applicable Gn/a Consult maintenance. (Name)_____________________________________________ G Applicable G N/A Consult l&E supervisors/block contact. (Names)__ G Applicable Gn/a Consult Computer/Programming Support. (Name), G Applicable Gn/a Consult parts supervisor. (Name)_______________ G Applicable G n/a Consult Operations. (Names)___________________ G Applicable G Applicable G n/a G N/A Evaluate and modify relief system. (Name)_______ Contact Industrial Hygiene/Environmental. (Name), G Applicable G N/A Contact Process Engineering. (Name)___________ G Applicable Gn/a Complete required reviews. (Name Them)_____________ G Applicable Gn/a CHAMPS - EMTS / P/PM Systems Updated. (List Them), G Applicable Gn/a ISO-9002 change - see ISO contact. (Name)___________ G Applicable G N/A GMP change - see GMP contact (Name)______________ G Applicable Gn/a Other. (Name Them)__ _________________ ;___________ Post-Modification Checklist (Before Startup) G Applicable Gn/a ________ Perform pre-startup audit (C-6). G Applicable Gn/a ________ Complete or update training program. G Applicable Gn/a ________ Job/Emergency procedures written and approved (see RL #604). G Applicable G N/A ________ Complete or update Reference Library (See Policy for Reviewing, Updating, and/or Creating Procedures - RL #S85). G Applicable Gn/a ________ P&ID's, process flowsheet and plot plans updated. G Applicable G N/A ________ Personnel trained on the change. G Applicable Gn/a ________ Computer code and documentation changed. APPROVALS: Originator_____ st Reviewer:_ nnal Reviewer: NAME: DATE: Completion Date:, gtdfAuguM 1. ItS4 1 on A 047004 CONF1 Df- NTT A! CHL0R-ALKAL1II MANAGEMENT OF CHANGE INTERNAL DOCUMENTATION CHECKLIST Check if Applicable: CATEG-OBV FI Heat and Material Balance Production Report / Calculations Freeze Protection 0 Heat Tracing List CD PSV Design Basis & Documentation CD Air Permit Documentation Log Sheets / Controlled Forms State Fire Marshal's Approval Mod5 Flow Diagram CD SQC Charts / Input CD Equipment Access / Congestion CD Mod5 Program Change Checklist CD Plant Files Updated CD Block Electrical Diagram CD Instrument & Electrical Loop Sheets (B6 & B7) CD Electrical Equipment Tests CD Field Switches / MCC Starters / Equipment Labels CD Critical Instrument Checklist Updated CD LAD Environmental Project Checklist Reviewed initials ( ( First Reviewer. Date: pWAugunt 1, It$4 C 2 DO A 047??5 CONFTDFNTIAl