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 have been corrected. On or about 16 July 2012, and at times prior thereto, the employer had open deficiencies pending from a compliance audit conducted on 10/19/2011 that were not corrected, exposing the workers to ammonia hazards, such as corrosive burns to the skin, eyes, and respiratory tract. A Task Assignments sheet dated May 10, 2012, had 24 listed items, with only 6 being resolved and marked as "Completed". A total of 3 had been marked as "In Progress", while the other 15 had either no comments on status or had a short comment. Of the 18 items still open, 7 involved Mechanical Integrity and 6 involved valves or piping issues. a) An example of a Mechanical Integrity issue was item# 13, which stated "Create AR for missing bolt in flange, valve 4A0-ISV-1200," assigned to B. Baggerly with a target completion date of 1/15/2012. This item had no comments noted and no status update; the item is still open and poses an ammonia hazard by the seal on the flange being compromised with the missing bolt. b) An example of an SOP issue was item# 19, which stated "Description of emergency shut-off valve operation," assigned to C. Davis (the PSM Coordinator) with a target completion date of 1/31/2012. This item had no comments noted and no status update; the item is still open and poses an ammonia hazard for anyone utilizing the emergency shut-off valve operation. Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date of this citation, the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking to ensure deficiencies on compliance audits are resolved in a timely manner.