Text For Citation: 01 Item/Group: 005 Hazard: CHEMNEP

29 CFR 1910.119(e)(3)(ii): The process hazard analysis did not identify any previous incident which had a likely potential for catastrophic consequences in the workplace: The employer does not address as part of the PHA previous incidents all of which occurred prior to the 2008 PHA being conducted but after the PHA done in 2003 or thereabouts that had the likely potential for catastrophic consequences in the workplace such as: a.Item 05/630-5D dated 7/28/2005 in which a release of bromine occurred as a result of the incorrect liner material used that was not suitable for bromine. Recommendation was action required by vendor for positive material indentification (PMI) b.Item 04/247-5D dated 3/5/2004 in which an unloading hose on a brine rail car ruptured. Recommendation was to update and/or revise the piping standards. c.Item 03/633-5D in which I-beams that hold up the #5 and #7 purification are corroded to the extent that webbing on the I-beam was missing. Recommendations were to put "caution" sign, no tarps allowed, no personnel allowed in 30 mph or greater winds. The incidents were not reviewed as part of the 2008 Bromine Unit PHA. These violations were observed on or about in the Bromine Unit where these conditions exposed employees to the hazards associated with uncontrolled releases of ammonia, chlorine, sulfur dioxide and/or bromine into the atmosphere. Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement date the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking to ensure that the process hazard analysis addresses any previous incident that had a likely potential for catastrophic consequences in the workplace.