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

29 CFR 1910.119(n): The employer did not establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan did not include procedures for handling small releases: Employees engaged in repair, replace, inspection and maintenance activities of covered process equipment at the engine rooms, roof top, and production floor areas were exposed to the hazards of inhalation of toxic ammonia, asphyxiation, chemical burns, and fire. At the facility the current Emergency Response Guidelines and the Disaster Manual did not address elements such as, but not limited to: a) Definition of a small release and protocols for responding to a small releases. b) SCBA level is not consistent. Liberal Emergency Response Plan (ERP) stated PPM to Escalate to SCBA is 250 PPM; SOP document stated SCBA Concentration above 300 PPM; and the MSA sensors in the engine rooms are set at 25 and 100 PPM. c) A formal written Emergency Action Plan is not developed or incorporated. 29 CFR 1903.19(d)(1) requires certification and documentation that the abatement of the above violation is complete.