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

29 CFR 1910.119(e)(3): The process hazard analysis shall address: 29 CFR 1910.119(e)(3)(vi): Human factors; and For the 2007 initial PHA and the 2013 PHA revalidation, the employer failed to address all human factors in the analysis. In that; a. The employer did not adequately address valve misalignment and the human factors in responding to valve misalignment, valve failures and/or other valve issues where valve information is not included or completely available in the digital control system/operator monitoring system, such as the amount of time taken to troubleshoot, identify the specific condition and then control hazardous system conditions or parameters during these situations. b. The employer did not address the human factor for employee exposure to hazardous conditions when troubleshooting, or responding to emergency situations involving open drain valves or securing manual isolation valves, such as the lack of any area monitoring for ethanol vapor in the facility or ensuring drain plugs in drain and sample valves. c. The employer did not address the human factors associated with loss of power and/or loss of process utilities. d. The employer did not address the human factors associated with incomplete standard operating procedures, to include evaluation of the amount of time necessary to respond to alarms and other control system indications before hazardous system conditions can occur.