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

29 CFR 1910.119(f)(1): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information addressing at least the elements listed in 1910.119(f)(1)(i)(A)-1910.119(f)(1)(iv): On or about January 05, 2022, KOCH and contract employees engaged in supporting, contracting, operating, inspecting, testing, and maintaining activities at the covered process equipment throughout the plant were exposed to potential release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injury to persons in and near the facility in that the employer failed to develop and implement clear instructions for safely conducting activities involved in each covered process consistent with the process safety information pertaining to the equipment. e) The Purge Gas Scrubber Startup, SUP KS11 01 18 007 Standard Operating Procedure (SOP), Revision #3.0 was deficient in that the Process Piping & Instrumentation Diagrams (P&IDs) was referenced without the ID or control number. Procedures xxxxx through xxxxx (Includes Hazmat Inventory Control), what procedure? The SOP procedural steps instruct employees to verify valve conditions, to open, close, or shut valves during operations, and emergency situations. Because of this reason, the P&ID must be identified in each of the SOP to be able to quickly reference, and to avoid confusion. Employees and contractors must immediately know what valves to open and close, which P&ID to review, to identity, to work with in case of emergency.