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

29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not address: Consequences of failure of engineering and administrative controls; a.) As of and prior to November 21, 2024, the employer's process hazard analysis (PHA) did not address the consequences of failure for the specific controls applicable to system components for hazard(s) control involved in the 3 ammonia refrigeration systems of mechanical room #1. The PHA report did not list individual or specific controls for the PHA team to address consequences of failure in the analysis. The 2017 PHA and 2021 PHA Revalidation only addressed generic engineering and administrative controls applicable to the hazards, such as procedures, mechanical integrity activities, training and safety switches, which did not allow the employer to 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 multiple 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.