Text For Citation: 01 Item/Group: 007 Hazard:

29 CFR 1910.119(d): Process Safety Information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process: a. The employer did not have a completed compilation of written process safety information (PSI) (as required for hazards of the chemicals, technology of the process and equipment in the process) for managers, engineers, operators, contractors and maintenance employees involved in operating and maintaining the process to understand the hazards of the process and equipment involving or affecting highly hazardous chemicals. The employer had not compiled and managed PSI for covered equipment; prepared files for each piece of equipment; populated those files with process safety information (PSI) required by 1910.119(d)(1)-(3), information utilized to document RAGAGEP compliance required by 1910.119(d)(3)(ii) and other process information, such as records of equipment operating conditions. b. The PSI package/binder for the 40R reactor process had not been updated since 1999. A process hazard analysis revalidation was performed for chlorination department in 2007. PSI affecting changes were made associated with the relief device system which formerly vented to a drum filled with water. c. The PSI package/binder for the 44R reactor process had not been updated since 2001. A process hazard analysis revalidation was performed for phosphites department in 2008. PSI affecting changes were made with a 2011 PCI3 piping circuitry project installation referred to as Main Street and with a 2011 vessel change and piping replacement project that increased production capability for this process. The replacement vessel was installed in October 2011. There was no information in the 44R equipment file for this new vessel. Appropriate information had not been populated into equipment files, or PSI files to maintain the information and have it available for use. d. The PSI package/binder for the 72R reactor process had not been updated since 2005. Significant equipment changes have occurred in phosphites since that time, some of which resulted in a change of process chemistry for this reactor process. Appropriate information was not populated into equipment files, or PSI files to maintain the information and have it available for use. e. PSI for the 133T PCI3 storage tank was unavailable following multiple changes, including new piping installation, replacement piping installation for repair and relief device design upgrade appropriate information. Required information was not populated into equipment files, or PSI files to maintain the information and have it available for use. Relief device design information was not available in the vessel equipment file, or PSI file(s). f. The PSI package/binder for the 35R reactor process had not been updated since 1999. This vessel had been part of a reactor system with the 36R reactor. Following its disconnection from the 36R reactor and beginning operations as a singly operating reactor, equipment files and/or PSI files were not updated with process information regarding chemistry changes, relief device design basis evaluation, isometric drawings used for installation verification related to the changes and pre-installation tests and inspections.