Text For Citation: 01 Item/Group: 026A Hazard: REFINERY

29 CFR 1910.119(l)(2)(i): The written procedures to manage changes did not assure that the technical basis for the proposed change was addressed prior to any change: The employer does not assure written MOC procedures address the technical basis for proposed changes prior to implementation of the change; MOC 96-034, "Install New Wet Gas Compressor" does not detail and address the technical basis for the change for the J-50 Wet Gas Compressor installed in the FCCU in 1997. Pursuant to 29 CFR 1903.19, the employer must submit an abatement plan within ten (10) calendar days describing the steps it is taking to ensure MOC specify and address the technical basis for changes, ensuring the procedure details and addresses items such as, but not limited to, what is to be changed, what is to be achieved by the change, and why the change is safe to make. The employer must also review all MOC procedures that must be retained for the life of the process due to their incorporation into part of the Process Safety Information (those MOC's addressing chemicals and equipment that will/have become part of the Process Safety Information (PSI) , thus giving the employer a documented record of the original design and design intent of the covered process and also providing a record of all changes to the process that are of importance to those responsible for safe operation and maintenance and to those that may need to consider future changes to the process). Every 30 days thereafter, the employer shall submit a progress report stating how many MOC have been updated, how many still need to be updated, whether it is meeting the schedule set forth in its abatement plan, and if not why not; and whether it is ensuring all subsequent MOCs address the technical basis for the change prior to making the change.