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

29 CFR 1910.119(e)(3)(i): The employer did not address the hazards of the process: The employer did not ensure that the process hazard analysis (PHA) was appropriate to the complexities of the process. The PHA did not identify, evaluate, and control the hazards of the compressors and evaporators in the engine room. The employer did not adhere to the What-If methodology, developed by the International Institute of Ammonia Refrigeration (IIAR), that it employed to determine and evaluate the hazards of the process. Caviness Beef did not correctly use the risk matrix system, assigning relative-risk rankings based on severity and probability in the 2010 process hazard analysis (PHA), such as but not limited to the following instances: a) PHA Items 1-12, 14, 15, 17 for the compressors indicated that the consequences of compressor failure would only be isolated ammonia release, possible injury, requiring first aid, no on site impact; inaccurately assessing the risk. b) PHA Items 1-4.1-4.6, 4.8, 4.10, 4.12, 4.13, 4,14, 4.15, 4.16 for the pressure vessels indicated that the consequences of pressure vessel failure would only be isolated ammonia release, possible injury, requiring first aid, no on site impact; inaccurately assessing the risk. c) PHA Items 1-6.1-6.11 for the relief valves indicated that the consequences of relief valve failure would only be isolated ammonia release, possible injury, requiring first aid, no on site impact; inaccurately assessing the risk. d) PHA Items 1-7.1, 7.3-7.8, 7.23 for the piping indicated that the consequences of piping failure would only be isolated ammonia release, possible injury, requiring first aid, no on site impact; inaccurately assessing the risk. e) PHA Items 1-8.1, 8.3, 8.4, 8.9-8.11 for the NH3 pumps indicated that the consequences of pump failure would only be isolated ammonia release, possible injury, requiring first aid, no on site impact; inaccurately assessing the risk. f) PHA Items 1-10.6, 10.6, 10.8, 10.9 for the start-up of existing or modified systems indicated that the consequences of failure during start-up would only be isolated ammonia release, possible injury, requiring first aid, no on site impact; inaccurately assessing the risk. g) PHA Items 1-11.1-11.3 for the shutdown of system indicated that the consequences of failure during shutdown would only be isolated ammonia release, possible injury, requiring first aid, no on site impact; inaccurately assessing the risk. h) PHA Item 1-12.1 for the emergency situation of system was specific tor a loss of electric power indicated that the consequences of emergency situation would only be isolated ammonia release, possible injury, requiring first aid, no on site impact; inaccurately assessing the risk. i) PHA Items 1-12.2-12.10 for the emergency situation of system indicated that the consequences of emergency situation would only be isolated ammonia release, possible injury, requiring first aid, no on site impact; inaccurately assessing the risk. j) PHA Items 1-13.3-13.5, 13.10 for the charging of NH3 to system indicated that the consequences of failure during charging would only be isolated ammonia release, possible injury, requiring first aid, no on site impact; inaccurately assessing the risk. k) PHA Items 1-14.3 for the pump-out of system indicated that the consequences of failure during pump-out would only beisolated ammonia release, possible injury, requiring first aid, no on site impact; inaccurately assessing the risk.