Text For Citation: 01 Item/Group: 007 Hazard:

29 CFR 1910.119(l)(1): The employer did not establish or implement written procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process: a) D2 Vinylidene Fluoride Process (VF2): The employer did not implement a management of change form for the discontinued use of the waste caustic discharge line, 20310, off of C-206, the primary monomer scrubber, on or about 2/9/16 b) D2 Vinylidene Fluoride Process (VF2): The employer did not implement a management of change form for the discontinued use of C203, the lights column, on or about 2/9/16. c) D2 Vinylidene Fluoride Process (VF2): The employer did not implement a management of change form for the installation of HS100, the 200 Area Shut Down Switch, on the DCS, on or about 2/9/16. d) D2 Vinylidene Fluoride Process (VF2): The employer did not implement a management of change form for the change in the testing procedure used for interlock ESS33214 for the gasholder compressor K-319, on or about 2/19/16. e) D2 Vinylidene Fluoride Process (VF2): On or about 5/12/16 the employer did not implement a management of change form for FR-72094, the flow recorder measuring low temperature glycol flow to the header, when it was bypassed due to malfunctioning. f) D2 Vinylidene Fluoride Process (VF2): On or about 5/14/16 the employer did not implement a management of change form FR-20301, the flow recorder measuring low temperature glycol flow, when it was bypassed due to malfunctioning. g) D2 Vinylidene Fluoride Process (VF2): On or about 4/22/16 the employer did not implement a management of change form FRC-20633, the flow recorder measuring well water flow to the C-205 tails tower, when it was bypassed due to malfunctioning. h) D2 Vinylidene Fluoride Process (VF2): On or about 3/6/16 the employer did not implement a management of change form FRC-20633, the flow recorder measuring well water flow to the C-205 tails tower, when it was bypassed due to malfunctioning. i) D2 Vinylidene Fluoride Process (VF2): On or about 2/9/16 the employer did not implement a management of change form for an LEL detector in the discharge piping from the dryers to the atmosphere that did not accurately measure flammability, on or about 2/9/16. NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.