Text For Citation: 01 Item/Group: 006B Hazard: REFINERY

29 CFR 1910.119(i)(2)(iv) The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process, training of each employee involved in operating a process has been completed. A) The pre-startup safety review did not confirm that training of each employee involved in operating a process had been completed prior to the introduction of highly hazardous chemicals to the process at Big West Oil, 333 W Center Street, North Salt Lake, UT 84054. This violation was identified during the inspection of the facility, on August 20, 2010, when the Compliance Officer reviewed the Pre Startup Safety Review (PSSR) document (BWO UOSH-122A-0004), 10-ALKY-03, P-318 Condensate Knockout pump replacement, during which the P-318 Knockout pump was replaced by a larger pump. The PSSR document (BWO UOSH-122A-0004) identified operator training completion as a requirement of the PSSR and the Department 2 Signature Sheet (BWO UOSH-122A-0002) for Operator training that was reviewed by the Compliance Officer did not include any dates of training for two B Crew Alky Operators who signed the sheet which indicates that they may have not received the required training prior to the introduction of highly hazardous chemicals to the process after the P-318 Knockout pump was replaced by the larger pump. The Condensate Knockout pump contents, as referenced in document BWO UOSH-101B-0160, includes hydrogen fluoride, a highly hazardous chemical. Not ensuring that employee training was in-place prior to introducing a highly hazardous chemical into the process may result in employee exposure to the hazardous chemicals of the process, to fire, or to explosion. This may be a system- wide occurrence that requires evaluation of all procedures throughout the facility.