Standard Cited:19100119 E06 Process safety management of highly hazardous chemicals.

Violation Items
Nr: 311611081 Citation: 01007 Issuance: 03/08/2010 ReportingID: 0524700
Viol Type:Serious NrInstances:2 Contest Date:03/31/2010
Abatement Date:04/19/2010 Nr Exposed:250 Final Order:
Initial Penalty:5000.00 REC: Emphasis:
Current Penalty:5000.00 Gravity:10 Haz Category:REFINERY



Text For Citation: 01 Item/Group: 007 Hazard: REFINERY
29 CFR 1910.119(e)(6): The employer did not ensure after the initial process hazard analysis that the process hazard analysis was updated and revalidated at least every five (5) years by a team meeting the requirements of 29 CFR 1910.119(e)(4): a.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer did not ensure a layer of protection analysis (LOPA) was performed as part of the company's process hazard analysis (PHA) revalidation of the FCC unit required by the company's PHA guidelines. The PHA for the FCC was conducted in April 2008, but as of September 10, 2009, the LOPA had not been performed to determine if hazards identified in the PHA resulted in recommendations requiring action. b.BP-Husky Refining, LLC - Oregon, Ohio: On or about September 10, 2009, the employer did not ensure corporate generic hazard scenarios which may result in a SIL 1 or lower safety instrumented system (SIS), were evaluated for a large number of process units. The company received the hazard scenerios in March 2009 and did not have plans on evaluating the hazard scenarios until May 2015. In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification. This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.