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

29 CFR 1910.119(d): Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process. 29 CFR 1910.119(d)(3): Information pertaining to the equipment in the process. 29 CFR 1910.119(d)(3)(ii): The employer shall document that equipment complies with recognized and generally accepted good engineering practices. On or about November 20, 2015, the employer did not document compliance with recognized and generally accepted good engineering practices (RAGAGEP) in that: a. The employer did not document RAGAGEP compliance and had not determined safe venting locations for pressure vessel sources when pressure vessels are the potential source of a relieving event. Pressure vessels with overpressure protection that vents to atmosphere include, but are not limited to the Rectifier column C-4201, Mole Sieve Bed #2 VS-4302, the Beer Column C-4101 and the Reflux Condenser E-4201. The ASME Boiler and Pressure Vessel Code, Section UG-135(f) is an example of RAGEGEP for discharging pressure vessels to safe locations. b. The employer did not document RAGAGEP compliance and had not designed, installed, evaluated and maintained the components of safety systems/interlocks used to monitor operating condition parameters and to control identified hazards associated with overheating and overpressure in process equipment in accordance with RAGAGEP. Safety systems/interlocks used to monitor and control hazards include, but are not limited to the Beer Column pressure instruments interlocked to stop flow into the column by controlling the supply pumps for alcohol containing "beer" into the column. The employer does not have calibration and testing of interlock components or monitoring system components in accordance with chemical process industry practice, manufacturer's instructions and has not documented compliance with RAGAGEP for safety systems, such as ANSI/ISA ANSI/ISA-84.00.01-2004 (IEC 61511-1 Mod), Functional Safety: Safety Instrumented Systems for the Process Industry Sector - Parts 1, 2 and 3.