Document qa4OpL6ZqLx5o68QopodNGJgR

LOSS PREVENTION AUDIT Page 1 Prepared bv: John Dizor. Jeff Harrison. Rov Kolder Date: 11-1-94 Reviewed bv: Buck Bailev Date: 12-13-94 A=Dow Rule or Regulation B=Good Practice/Training C--Hazard Analysis VII. AUDIT QUESTIONS AND ANALYSIS Operating Discipline REFERENCE: Operating Discipline Standard for The Operating Units of Dow U.S.A. 1. Yes D No [X] Have you filled out the plant self-evaluation forms to assess your plants progress on Operating Discipline? Please provide these forms at the pre-audit meeting. Section II Process Technology Documentation Section V Process Risk Management Section VI Operating Procedures Section VII Process Control Section VIII Operational Reliability Section IX Dynamic Process Information Section XII Industrial Hygiene Plans: Presently working on assessment per Division and Plant goals. A/B 2. Who has primary responsibility for the plant's Operating Discipline? Presently Plant Superintendent. A/B 3. How is the written portion of the Operating Discipline program maintained? (Have this available,at the audit meeting.) Procedures are stored in the-MicroVaX' Computer System "Reference Library" Training Programs HPT) on computer and maintained bv the Training Coordinator. A 4. Process Safety Information (OSHA 1910.119, Paragraph d)(Review the Operating Discipline Self-Evaluation on Process Technology Documentation, Process Risk Management, Industrial Hygiene.) (Revised 02/18/94; cmk) 3/28/95; LAD:bwb DO A 0470 CONFIDENT! LOSS PREVENTION AUDIT Page 2 a. Is information included pertaining to the hazards of the chemicals used or produced by the process, and does the information include at least: YES NO X Toxicity Information X PEL'S X Physical Data X * Reactivity Data X Corrosivity Data X Thermal and Chemical Stability Data X Hazardous effects of inadvertent mixing of different materials that could forseeably occur? NOTE: MSDS's meeting the requirements of 29 CFR 1910.1200(g) may be used to the extent they contain the information required. b. Is information included concerning the technology of the process, and does it include at least: YES X NO * A block flow diagram or simplified process flow diagram? Mod Graohics. IPT X * Process Chemistry? IPT X * Maximum intended inventory? IPT & Emergency Plan X * Safe Upper and Lower Limits? ODerating Parameters - Log Sheet X An evaluation of the consequences of deviations? ( If the original technical information no longer exists, it may be d eveloped in conjunction with the Process Hazard Analysis.) c. I s information included pertaining to equipment in the process, and does it include at least: YES X X NO Materials of Construction? IPT * Piping and Instrument Diagrams (P&ID's)? X Electrical Classification? X * Relief System Design and Design Basis? Engineering N/A * Ventilation System Design? X Design Codes and Standards Employed? X Material & Energy Balances for Processes Built after 05/26/92? X * Safety Systems (e.g., interlocks, detection or suppression systems) (Revised 02/18/94; cmk) 3/28/95; LAD:bwb DO A 047076 CONFIDENTIAL LOSS PREVENTION AUDIT Page 3 A 5. Operating Procedures (OSHA 1910.119, Paragraph f) (Refer to Operating Discipline Self-Evaluation on Operating Procedures) Yes [Xj No Do written operating procedures exist for each process? Yes [X] No Do the procedures provide clear instructions for conducting activities safely? Do the operating instructions address, as a minimum, steps for each operating phase, including? YES X X X X NO Initial Start-up? Normal Operations? X Temporary Operations? X Emergency Shut Downs? X Conditions Requiring Emergency Shut Down? X Assignment of Shut Down Responsibility to Qualified Operators? X Emergency Operations? Normal Shut Down? Start-ups following a turnaround or emergency shut down? Yes [X] No Are operating procedures readily accessible to employees who work in or maintain a process? Yes [X] No 0 Are operating procedures reviewed as often as necessary to assure that they reflect current operating practice? A/B 6. Yes [X] No 0 Does the plant have a training process to keep people current on Operating Discipline? Plans: MOC process and 3-vear retraining/certification per PSM Communication System with documentation. (Revised 02/18/94; cmk) 3/28/95; LADrbwb DO A 047027 00NFTDFNTTA1