Text For Citation: 01 Item/Group: 010 Hazard: REFINERY

29 CFR 1910.119(o)(1) Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed. A) The employer at Big West Oil, 333 W Center Street, North Salt Lake, UT 84054, did not verify that procedures and practices developed under the standard are adequate and being followed. In the March, 2009 Compliance Audit performed by Z Engineering and Environmental Services, Inc., the auditor failed to discover the lack of written procedures to maintain the on-going integrity of process equipment as required by 1910.119(j)(2) of the PSM Standard. The auditor claimed: "BWO has a written PSM program that addresses all sections of the PSM rules" (BWO UOSH-039B-0004). This statement would imply that the auditor had found written procedures to maintain the on-going integrity of process equipment as required by 1910.119(j)(2) of the PSM Standard. OSHA inspectors unsuccessfully made every effort to discover written policies and procedures based on RAGAGEPs for the activities of design, construction, inspection, repair, alteration, rerating, and fitness for service as applied to pressure vessels, piping, pressure relief valves, relief vent systems, instrumentation, controls, and pumps. Most of the submitted written procedures from BWO related to preventive maintenance and OSHA concluded that there were inadequate written procedures for the other elements of Mechanical Integrity such as; design, construction, inspection, alteration, rerating, and fitness for service for covered equipment. Despite the audit being only a "snapshot", the auditors should have easily discovered the paucity of written procedures that could reduce the potential of employees exposures to hazardous chemicals. The auditor incorrectly concluded that the employer could meet the intent of 1910.119(j)(2) of the PSM Standard by merely listing the applicable standards and codes and that written procedures were not required. The auditor writes: "The BWO Mechanical Integrity Equipment Reliability Program references standards and codes used for construction, manufacture and maintenance of refinery equipment. These standards appear to represent recognized and generally accepted good engineering practices" (BWO UOSH-039B-0032). This may be a system-wide occurrence that requires evaluation of all incident reports and recommendations throughout the facility.