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

29 CFR 1910.119(e)(1):The employer shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. Employers shall determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process. a.) As of and prior to November 21, 2024, the employer's process hazard analysis (PHA) was not appropriate to the complexity of the process and did not identify, evaluate, and control the hazards involved in the 3 ammonia refrigeration systems of mechanical room #1. The 2017 PHA and 2021 PHA Revalidation only addressed generic equipment in a generic ammonia refrigeration process, such as compressors, evaporators, pressure vessels, condensers and instruments and this generic approach did not identify, evaluate, and control the hazards from variations in equipment design, safe upper and lower operating and design limits, and operating and maintenance procedures for the types of equipment involved in the mechanical room #1 covered process. Due to the continued operation of a process which has not appropriately identified, evaluated, and controlled the hazards of the process by a PHA, employees have increased risk for exposure to ammonia released from the system(s) leading to corrosive injuries, burns or struck by injuries from fires and explosions, or death. b.) As of and prior to November 21, 2024, the employer's process hazard analysis (PHA) was not appropriate to the complexity of the process and did not identify, evaluate, and control the hazards involved in the 3 ammonia refrigeration systems of mechanical room #1. The 2017 PHA and 2021 PHA Revalidation only addressed a generic process with generic engineering and administrative controls applicable to the hazards, such as procedures, mechanical integrity activities, training and safety switches, which did not allow for the employer to determine if the hazards are appropriately controlled and analyze the listed controls for the consequences of failure of those engineering and administrative controls which result from variations in equipment design, safe upper and lower operating and design limits, and operating and maintenance procedures for the types of equipment and controls involved in the mechanical room #1 covered process. Due to the continued operation of a process which has not appropriately identified, evaluated, and controlled the hazards of the process by a PHA, employees have increased risk for exposure to ammonia released from the system(s) leading to corrosive injuries, burns or struck by injuries from fires and explosions, or death.