Text For Citation: 01 Item/Group: 001 Hazard: CHEMICAL

29 USC 654: Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employmnent and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to: a/ Employees changed out 100# cylinders of hydrogen fluoride connecting the cylinders to a production process without being protected from the potential of pressure release of hydrogen fluoride during the line breaking procedure. AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THIS HAZARD IS....the placement of a pressure regulator on line with pressure relief control venting to the scrubbers or other safe location. The system would be so constructed that any excessive pressure which could damage or threaten the safety of the process and the employees would be vented to a safe location prior to the pressure reaching the process. A second feasible and acceptable abatement method would be to place valves and pressure gauge on line such that the pressure on the cylinder would be known by opening the first valve providing pressure to reach the pressure gauge so that the pressure on the system could be determine before the valve connecting the cylinder to the process was opened. A method of releasing the pressure if necessary would be provided through a pressure relief valve vented to the scrubber or other safe location. With any abatement, the abatement must include the development and implementation of a written safe work practice describing the step by step process of the steps to take to bring to change out a cylinder of HF from the process. and the steps to be taken if excessive pressure is released from the cylinder during that cylinder change. Abatement certification and abatement documentation is required for this violation. The documentation should include written verification of abatement, applicable measurements of monitoring results, and photographs or videos which you believe will be helpful. The abatement certification sheet is enclosed with this citation(s).