Text For Citation: 01 Item/Group: 002 Hazard: CHEMNEP

29 CFR 1910.119(e)(5): The employer did not establish a system to communicate the actions to be taken, as a result of the process hazard analysis team's recommendations, to operating, maintenance and other employees whose work assignments are in the process and who could be affected by the recommendations actions: a)At the establishment, the employer did not communicate the resolutions/actions of the initial findings and recommendations resulting from the 1993 Process Hazard Analysis and all other Process Hazard Analysis Audits since 1999 to present to the Ammonia Department employees such as, but not limited to, operators, maintenance employees, and hazardous chemical release responders. Employees were exposed to catastrophic release of ammonia which result in asphyxiation, explosion and flash fire leading to death and injury to persons in and near the facility. b)At the establishment, the employer did not communicate the findings and recommendations of the 2008 Process Hazard Analysis (PHA) revalidation study to the Ammonia Department employees such as, but not limited to, operators, maintenance employees, and hazardous chemical release responders. The employees were not provided the recommendations and answers to a series of What-If questions that were part of the 2008 PHA study. The What-If questions of the 2008 PHA included, but were not limited to, the What If condition of one, or more manual shutdown switches that were located outside of the engine room(s), but were not accessible, and/or might not be operable at the time of an uncontrolled release of Ammonia from the system. The consequences of an inaccessible, or inoperable manual shutdown switch included, but were not limited to employee exposure to Ammonia, and/or a catastrophic fire due to Ammonia contact with an ignition source. 29 CFR 1903.19(d)(1) requires certification and documentation that the abatement of the above violation is completed.