Text For Citation: 01 Item/Group: 003 Hazard:

29 CFR 1910.119(e)(3): The employer did not ensure that the Process Hazard Analysis methodology used addressed the following: (i) The hazards of the process; (ii) The identification of any previous incident which had a likely potential for catastrophic consequences in the workplace; (iii) Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.); (iv) Consequences of failure of engineering and administrative controls; (v) Facility siting; (vi) Human factors; and (vii) A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace. a. On or about September 14, 2018, the employer had used a Checklist methodology for the Process Hazard Analysis for the manufacture of explosives that did not adequately address standard requirements in subsections (i) through (vii). b. On or about September 14, 2018, the employer had used the written Work Instruction (WI) for the manufacture of the T460 Blast Strips to list hazards for that manufacturing process that did not adequately address standard requirements in subsections (i) through (vii), including a failure to evaluate hazards to employee foot traffic around the Diversion Building along the sidewalks within 5 feet of the blast booth blow-out panels.