Text For Citation: 01 Item/Group: 004 Hazard:

29 CFR 1910.119(f)(1)(i): The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements: (I) Steps for each operating phase: [A] Initial startup [B] Normal operations [C] Temporary operations [D] Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner [E] Emergency operations [F] Normal shutdown [G] Startup following a turnaround, or after an emergency shutdown On or about October 14, 2020, the employer's written operating procedures were inaccurate in the following instances: a) The operating procedures to move propellant from the tank farm into the gashouse had instructions to open globe valves for the north pump skid, but the pump skid has ball valves and not globe valves. b) The operating procedures for moving aerosol to the gas house and for operating the gas house equipment did not address emergency shutdown, conditions under which emergency shutdown is required, or assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner. This exposed employees to fire and explosion hazards from the release of flammable liquids and gases in aerosol filling operations.