(122a) Improving Process Safety by Addressing the Human Element

To present the reasons for initial development, discuss the elements and their direct impact on reducing human errors, challenges in implementation of a global policy and ongoing activities to ensure global compliance.

The reasons for initial development would include background discussion on what prompted development of our Conduct of Operations in 1998. 1996 was a challenging year in Celanese regarding process safety. This challenge was to improve our overall process safety and reduce the human error element in operations. In 1997 a study of our process safety programs lead to the development of our Conduct of Operations white paper and in 1998 this paper was approved for implementation.

The element discussion would include a short discussion on each element. The discussion would include respective sub elements with a level of detail to explain its relevant impact on the reduction of human errors. The set of elements and respective sub elements include:

? Standard Operating Procedures: Usage, Control and Development

? Operations Training: Program, On the Job Training, Trainee Control, Testing, Required Reading.

? Operations: Process Safety Officer, Operations Shift Change, Maintenance/Operations Turn-over, Verification after Maintenance, Communications, Inhibiting Safety Systems, Labeling, Housekeeping, Management of Change, Lighting, Tool Management, Control of Access to the Unit

? Management Review and Audits

The challenges would detail those presented to implement in each of our sites in North America, Mexico, Canada, Singapore and China (approx 16 sites). This includes the development of standard formats, training programs, SOP templates and human factored direction. These challenges would included: resource requirements for initial implementation and resource requirements of ongoing compliance, changing current site processes to be in compliance with Conduct of Operations, and operator acceptance of the above elements plus hurdles we faced to over come and solution we enacted to implement at each site. Finally, to discuss our current activities to develop the Conduct of Operation into a formal global standard work process (policy) and our ongoing activities to ensure compliance of all the above elements.