Text For Citation: 01 Item/Group: 006A Hazard:

29 CFR 1910.119(e)(3)(iii): The process hazard analysis did not address engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases: a) Ethylene Oxide Continuous Plant, Croda-Atlas Point. - On or about November 25, 2018, the employer failed to address the need for an effective advanced warning ethylene oxide area detection system for employees required to investigate an ethylene oxide release. b) Ethylene Oxide Continuous Plant, Croda-Atlas Point. - On or about November 25, 2018, the employers facility siting study (Croda Atlas Point Facility Siting Study Revised Report, November 2, 2015) identified that the EO Control Room was in an area of potential toxic release consequences/hazards, however, neither the facility siting report or the 2016 Updated PHA included engineering controls (i.e., equipment/building features) such as, but not limited to, the following: -sensors in the air intakes to alert the occupants of the ingress of hazardous materials, -means to automatically limit air ingress from HVAC systems in the event of a sensor alarm; -appropriately sealed windows and doors -appropriate PPE; or -administrative controls such as emergency procedures that designate the building as a place to immediately evacuate upon detection/notification of a toxic/flammable materials release. c) Ethylene Oxide Continuous Plant, Croda-Atlas Point. - On or about November 25, 2018, the employer failed to address the adequacy of the firewater supply with respect to the deployment of the water deluge systems and firewater monitors to contain and quell a release of ethylene oxide. These conditions contributed to employee exposure to the toxic, fire, and explosion hazards posed by ethylene oxide.