Document RJ1QDKXrReY2ZKRDvg242QJD7

FORM 203 -- L*"t CH1AI.M LA. CHEMICALS i HATH tOM (10) 70OJt4 INTEROFFICE / LAKE CHARLES TO Mr. A. T. Raetzsch FROM J. G. Peck confideimtial RK'D AUG 3119 JI DATE August 30, 1971 SUBJECT Summary Report of OSHA Compliance Survey Reference: (l) Memo from Widing to Raetzsch et al, June 22, 1971 (2) Memo from Duncan to Widing, July 6, 1971 In mid-July of 1971 a task force was assigned the joh of deter mining the status of the Lake Charles plant with regard to rules arid regulations issued under the Occupational Safety and Health Act of 1970. The "basis and results of this survey are discussed in this report. iMa "Act" includes more than just the regulations issued in the May 29, 1971 Federal Register. It also includes those regulations promulgated under the Walsh-Healey Public Contracts Act, as Amended (klU.S.C.35) and several other acts. It is almost impossible to untangle all the regulations involved; so, as a practical matter, two documents were used as a basis for the survey as follows. 1. Occupational Safety and Health Standards, Rational Concensus Standards and Established Federal Stan dards as published in the Federal Register dated May 29, 1971. 2. Inspection Survey Guide for Federal Contracts Programs, Bulletin 326 (Inspector's guide for com pliance with Walsh-Healey Act). Some of the regulations in the Federal Register have delayed effec tive dates, but the survey was handled as if all regulations were in effect since the delays would, in general, still permit these regulations to become effective during the period of the initial compliance effort. The plant was indexed by physical areas and non-compliance items listed on this basis. Order of magnitude estimates have been tabu lated for each item. It should also be recognized that no costs have been allowed for procedural changes, inspections or record keeping. -Most of these costs will be indirect in nature and will be most difficult to define prior to actual implementation of the item in question. 0000261 | Mr. A. T. Eaetzsch Z August 30, 1971 In answer to the request which "brought about this survey, the estimated cost for full compliance with the Act will be $3>5^J1J+1 and will re quire about two years to complete. A breakdown into categories as re quested by J. E. Burrell is as follows. a. Hiose items which can be Instituted at minimal cost and time. (We interpreted this as expense items of $1000 or less.)--------------- ---- ----------------- $8l,4ll b. Diose items which will require considerable time and/or expense but not in the magnitude of capital expenditure (expense items of $1000 or more). --------------------------------------------------------------------- $598,273 c. Those items which will require capital authorization (all capital items)---------------------------- $2,864,457 As would be expected with a program of this type, many of the regula tions are not clear; some go too far into details allowing no leeway; some important subjects are not covered by specific standards at all but mentioned in terms of vague, general requirements. There are other regulations which simply do not appear to be reasonable. Be cause this condition exists, it would appear to be unwise to embark on a program of complete, unquestioning compliance with this Act. Consequently, it is recommended that we proceed on a basis similar to that outlined in Table I where jobs are grouped into classes with an identifying code. The code is identified in the attached Table I along with totals of costs when broken down according to the code system. In way of explanation. Code 1 and 2 items are more or less valid and deal directly with health in a broad sense and with personal safety. Code 3 items are those where we do not comply because of a technicality or the standard is questionable. One example i3 lighting levels; it is almost inconceivable that lighting levels in the standard are really desirable or necessary. A further example is handrail toeplates where the space at the bottom of the toeplate is limited to 1/4" while the majority of those in the plant are 1/2" or so above the walkway. Code 4 items for the most part are items which have had some consideration in the past and it is generally agreed that something must be done. These items fall under regulations which are not entirely definitive, espe cially in the area of heat stress. We should be sure that our solu tions for these problems will 3tand up under the regulations before proceeding. JGP:ds Attachment: Table I ec; B. E. Baker D. L. Duncan 0. L. Cromeans V. Graybil M. Davis W. Melton AREA TOTAL CODE ^ CODE #2 CODE #3 CODE #4 000 - Plantwide 001 - Brine Treatment (a) 002 - Future Ammonia (a) 005 - Powerhouse "A" & Riverwater Pump House (A) OOu - Powerhouse "B" (a) 007 - Cylinder Loading & Public Relations (A) 008 - Diaphragm Cells, Maint. Shops & Laboratory (a) 009 - Caustic Production & Kail Shipping (a) 010 - Chlorine Liquefaction & Rail Shipping Oil - Dock Storage & Docks (A) 012 - Chlorate (A) 013 - IPP (A) 018 - Organic Storage & Rail Shipping (b) 019 - Mercury Cells (A) 025 - Anhydrous Caustic (A) 050 - Adm. Bldg. & Storerooms (A) 060 - EDC (B) Oul - Tri-Ethane (b) 062 - HC1 (B) 053 - OHC-Per-Tri (B) 064 - Ethyl Chloride (b} O65 - Vinyl Chloride (B) 0G0 - Silica Pigments 100 - Butadiene Storage So Salvage Area (A) 101 - Sportsman Lake 110 - Sulphur Brine Field 111 - Starks Brine Field $ 211,758 17,729 59,871 137,817 125,628 18,571 1,158,051 139,012 117,053 156,277 105,504 12,701 64,373 276,255 48,071 96,581 40,910 46,534 35,923 109,450 24,430 37,916 468,446 25,880 500 5,900 3,000 $ 80,435 9,955 8,695 41,928 19,785 5,175 148,035 77,650 80,4l4 15,575 8,290 2,750 32,005 18,720 6,760 24,960 11,065 11,450 16,811 44,170 10,670 10,740 30,015 2,400 - 4,625 2,100 $ 34,580 500 46,100 21,410 $ 71,743 7,274 5,076 74,479 $ 25,000 - 13,530 2,150 92,313 11,246 - - 14,994 505,022 490,000 1,950 59,412 - 2,310 34,329 - 800 1,700 1,100 930 139,902 25,514 8,851 31,438 - 70,000 - - 7,600 100 1,200 1,000 1,300 -1 1,400 - - 70 - 99,935 41,211 70,421 28,695 33,784 19,112 63,880 13,760 27,176 70,361 23,400 150,000 - - 150 - - - - - 368,000 - 500 - - 1,275 900 - TOTALS 3,544,141 725,258 155,224 1,560,509 1,103,150 .CODES; 1. Item directly affects health or safety and should be done as soon as possible. 1-- 1 2 Item does not immediately affect health or safety, but should be done on a low priority basis. lt I co I I co t It IoI (OI Io1 3. Item does not meet regulations because of technicality -- hold and contest if required or ask for variance 4. Item represents known hazard, but regulations not definitive enough to risk attempt at corrective action - hold and force definition. 1ol t N) I TABIE I '1 I O' t I u> 1 II