Text For Citation: 01 Item/Group: 048 Hazard:

29 CFR 1910.119(l)(2)(ii): Management of Change. The procedures shall assure that the following considerations are addressed prior to any change: Impact of change on safety and health: Prior to a change, the impact of change on safety and health was not considered for the following management of change (MOC) processes, including but are not limited to: a. MOC-12-049: The MOC for replacing damaged PVC lines did not adequately address the impact on safety and health, in that it did not address the impact of potential runaway reaction temperatures or other scenarios resulting in venting to the scrubber, exceeding the replacement material specifications for the scrubber vent lines that connect the phosphites reactors to the building wet scrubber process equipment. b. MOC-12-058: The MOC process for replacing the 34R demister with a spool piece did not address safety and health impact. c. The MOC for the 247T conversion to a production reactor did not address the impact of converting the tank to a reactor on employee safety and health. d. Phosphites department 44R process: The MOC RFC 11-005 did not address the impact on safety and health for increasing vessel capacity regarding the impact on relief device protection by certifying the design and design basis documentation, evaluating safety systems and pipe pressure testing documentation.