Perform a comprehensive third-party audit of the Geismar facility’s process safety and allied management systems as soon as practicable. The audit shall:
A. Be performed or led by an individual, firm, or team meeting the requirements outlined in paragraphs (b), (c), and (d) of Appendix E of this report.
B. Evaluate compliance with applicable federal standards (40 C.F.R. § 68 and 29 C.F.R. § 1910.119). In particular, the audit shall include the required elements that contributed to these incidents, including but not limited to:
1. management of change;
2. mechanical integrity;
3. quality assurance;
4. pre-startup safety reviews;
5. operating procedures; and
6. contractor management.
C. Evaluate other internal management systems that contributed to these incidents. In particular, the audit shall include but not be limited to:
1. management of organizational and personnel change;
2. management of safety-related capital projects;
3. organizational resilience; and
4. safe work practices including, but not limited to:
a. work permitting;
b. preparation of equipment for maintenance;
c. control of hazardous energy;
d. line break safety; and
e. personal protective equipment.
D. Use the Center for Chemical Process Safety’s Guidelines for Auditing Process Safety Management Systems as guidance to verify both the suitability of these systems and their effective, consistent implementation and performance.
E. Result in the development of a comprehensive report meeting the requirements outlined in paragraphs (e) and (f) of Appendix E of this report. If any findings are rejected, the rationale for and documentation supporting the merit of the rejection shall be included. The report in its entirety shall be made available to the Honeywell workforce at the Geismar, Louisiana; Baton Rouge, Louisiana; and Metropolis, Illinois, sites.