Text For Citation: 01 Item/Group: 008 Hazard:

29 CFR 1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies had been corrected. On or about 10/10/18, at the LCY Elastomers facility located in Baytown Texas, the employer did not ensure 2016 PSM compliance audit findings had been corrected such as but not limited to: a. Item #4: Develop a system and method, such as a PSM bulletin board, to ensure employees, including contractor employees, and their representatives have been provided access to process hazard analysis and other information required by the standard; b. Item #10: Conduct an in-depth PSM/RMP refresher/initial training for site PSM/RMP stakeholders and perform a proficiency test to ensure facility staff understands the training given and can readily identify the hazards of highly hazardous chemicals used or produced by the process. c. Item #46: Conduct and incorporate facility siting study information in the PHA evaluation and include specific provisions for evaluating facility siting in general as it pertains to mitigating hazards that could lead to catastrophic events. d. Item # 53: Establish a tracking methodology to address open PHA recommendations. e. Item # 123: Develop a comprehensive and standardized permit system and implementing/updating/verifying safe work practices and procedures for lockout/tagout. f. Item # 170: Establish a formalize MI task list with results of tests and inspections documented properly. g. Item #265: Update and implement the LCY emergency planning and response and emergency action plan procedures. h. Item # 266: Update the emergency action plan to include procedures for handling small releases and spills. i. Item #424: Review all contractors performing work at the site on or adjacent to covered processes against the applicability of the requirements in this contractor paragraph. Review applicable contractor's PSM program consistency with LCY PSM requirements. j. Item # 432: Develop and implement a program to periodically evaluate the contractor employers' responsibilities under the PSM Standard.