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

29 CFR 1910.119(f)(3): The operating procedures were not reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer did not certify annually that these operating procedures are current and accurate. On or about 16 July 2012, and at times prior thereto, the employer had operating procedures in place being utilized that had not been annually certified per regulatory standard, exposing personnel to various ammonia hazards during operations. a) An example is the Emergency Shutdown procedure (Procedure ID: SA-A-AG-016) that has the steps for shutting down the ammonia injection system, which states that the Fogging System Start Button is 4FP-HS1-0410. However, the button is labeled as 4FP-HS3-0430, which may cause confusion regarding its use in an emergency, and that the system and/or button may not be maintained. b) Another example of an SOP issue was item# 19 on the Compliance Audit, which stated "Description of emergency shut-off valve operation," assigned to C. Davis (the PSM Coordinator) with a target completion date of 1/31/2012. This item had no comments noted and no status update; the item is still open and poses an ammonia hazard for anyone attempting to utilize the emergency shut-off valve operation. Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date of this citation, the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking to ensure all operating procedures are reviewed as often as necessary, and certified annually to ensure they are current and accurate.