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

29 CFR 1910.119(e)(2): The employer shall use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed. 29 CFR 1910.119(e)(2)(iv): Hazard and Operability Study (HAZOP); For the 2013 process hazard analysis (PHA) revalidation; the employer did not appropriately apply their identified HAZOP PHA methodology to systematically identify hazards in covered processes, identify controls used and evaluate the consequences for failure of those controls resulting in an inadequate determination and evaluation of hazards in the covered processes exposing employees to the hazards related to fire and explosions related to flammable liquid and/or vapor release from ethanol processing equipment. Examples of the inappropriate and/or inadequate application of the methodology include, but are not limited to: a. The HAZOP methodology was not properly applied in an appropriate or adequate manner, in that systematic nodes were not developed to be analyzed for hazards from one point of process flow to the end of that process node. b. The HAZOP methodology was not properly applied in an appropriate or adequate manner, in that, the Guide Word deviation related Causes are not linked to specific Consequences. Consequences are not linked to specific Existing Safeguards. Existing Safeguards or specific Consequences are not linked to specific Suggested Actions (or Recommendations.) The analysis was not systematically applied to the process by application of the process parameter or condition and Guide Word deviation to each process point by linking to a specific Cause, which is linked to any specific Existing Safeguards and then linking to any specific Suggested Actions (or Recommendations.) c. The HAZOP methodology was not properly applied to the hazard analysis in that there was a lack of detail, or specificity in identifying specific equipment and locations in the ethanol process in the analysis. The revalidation failed to systematically detail specific equipment and/or location(s) in the process to Guide Word parameters for deviation(s), to Causes and to Consequences.