Text For Citation: 01 Item/Group: 004 Hazard:

29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions. Instance a). On or about 10/10/18, at the LCY Elastomers facility located in Baytown Texas, the employer did not resolve 2014 PHA recommendations for 500, 800 and 900 areas in a timely manner such as but not limited to: · Item #5: Review refrigerated water pressure indication to confirm it has an associated alarm; · Item #6: Add an alarm on low flow nitrogen supply to H-7902. Instance b). On or about 10/10/18, at the LCY Elastomers facility located in Baytown Texas the employer did not resolve 2016 PHA recommendations for 300, 400 and 600 areas in a timely manner such as but not limited to: · Item #1: Evaluate current instrumentation to ensure adequate monitoring for vacuum in the blend tank process area; · Item#17: Redesign sample point on reactor R-7301; . Item #18: Evaluate PCV 30176 operation associated with reverse flow; evaluate installation of double check valves; · Item #21: Consider reliability of flexible connection and ability to limit leaks to lessen chance of catastrophic release.