Document vpE6V1XkgLRMvJnpE57L9B2R

PSM AUDIT wmM Eleven- Application 1910.119(a) Employee Participation 1910.119(c) Process Safety Information 1910.119(d) Process Hazard Analysis ' 1910.119(e) g Operating ^ Procedures 1910.119(f) > > <r> <L.~ IMPROVEMENT OPPORTUNITIES uppiLOUISVILLE PVC FACILITY ^^^9401 1 Develop an index for the plant's PSM program which includes the logic for including and excluding processes and person/position responsible for managing the program. ~ Responsbil.ty 1994 Target 'Date EP9402 0^ PS 19403 Recommend that SA-609 employee participation procedure be revised to more clearly outline how employees are consulted for their participation in the PSM program. Include current VCM MSDS. electrical classification drawing^- -- S'TTU-u opetU in the process information file. Also add VCM spheres to block flow diagram, oy, XP PSI9404 ^ PHA9405 (=)HA9406 jPHA9407 \VPHA9408 . Develop a comprehensive index to the process information filing system to address each subpart of this paragraph. Document rationale for priority utilized to complete HAZOP's. Provide a system to resolve PHA recommendations in a timely manner and communicate findings to appropriate plant X&c people. Previous incidents are being considered, but this action is not always documented nor is an explanation of how the information will be included. Recommend that as PHA's are conducted any applicable engineering standard or code referenced in HAZOP be documented. V$e 'Inhs \o o\)a/' 0c r l OP9409 Certify annually all operating procedures represent actual field operations and current technology. ^ OP9410 Address consequences of process deviation and steps required to correct or avoid these deviations. or\ a-w