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

29 CFR 1910.119(f)(1): Written operating procedures providing clear instruction for conducting operations in a covered process safely and consistently with process safety information addressing all of the elements listed in 29 CFR 1910.119(f)(1)(i) through 29 CFR 1910.119(f)(1)(iv) have not been developed and/or implemented: (a) Location - 638 Summer Street, Lynn, MA: On or about 5/1/2017, the written operating procedures associated with the manufacture of Product did not address emergency shutdown including under what conditions emergency shutdown is required and who is responsible for conducting emergency shutdown. (b) Location - 638 Summer Street, Lynn, MA: On or about 5/1/2017, the written operating procedures associated with the manufacture of Product did not address the consequences of deviation from operating limits. (c) Location - 638 Summer Street, Lynn, MA: On or about 5/1/2017, the written operating procedures associated with the manufacture of Product did not address steps required to correct or avoid deviation. (d) Location - 638 Summer Street, Lynn, MA: On or about 5/1/2017, the written operating procedures associated with the manufacture of Product did not address the properties of and the hazards presented by the chemicals used in the process. (e) Location - 638 Summer Street, Lynn, MA: On or about 5/1/2017, the written operating procedures (SA-002 - Personal Protective Equipment Section, SA-004 - Personal Protective Equipment Section, S-014 - Personal Protective Equipment Section, S-015 - Personal Protective Equipment Section, U-005 - Personal Protective Equipment Section, and U-015 - Personal Protective Equipment Section) associated with the manufacture of Product and related to personal protective equipment were not implemented. These operating procedures require the use of flame-resistant clothing (FRC) as a necessary precaution to protect operators during the manufacture of Product; however, the employer did not provide FRC or require, in practice, that it be used when operators conducted activities such as loading solid ingredients to heated flammable liquids through the manway of the reactor. This hazardous condition exposed employees to the hazard of flash fires. (f) Location - 638 Summer Street, Lynn, MA: On or about 5/1/2017, the written operating procedures associated with the manufacture of Product did not address control measures to be taken if physical contact or airborne exposure occurs. (g) Location - 638 Summer Street, Lynn, MA: On or about 5/1/2017, the written operating procedures associated with the manufacture of Product did not address fire protection systems and other safeguards credited in the 2015 HAZOP including the temperature indicator and recorder.