Text For Citation: 01 Item/Group: 013 Hazard:

29 CFR 1910.119(i)(2)(ii): The pre-startup safety review did not confirm that safety, operating, maintenance, and emergency procedures were in place and were adequate prior to the introduction of highly hazardous chemicals into a process: a) Ethylene Oxide Continuous Plant, Croda-Atlas Point. - On or about November 25, 2018, the employer failed to assure that Control Room evacuation procedures in the event of toxic ethylene oxide infiltration were developed and implemented to minimize employee exposure to ethylene oxide. b) Ethylene Oxide Continuous Plant, Croda-Atlas Point. - On or about November 25, 2018, the employer failed to assure that emergency operating procedures were developed and implemented to mitigate an ethylene oxide leak including specific steps to isolate/de-inventory quantities of ethylene oxide to a safe location. c) Ethylene Oxide Continuous Plant, Croda-Atlas Point. - On or about November 25, 2018, the employer failed to assure that written[HA-O2] procedures were developed and implemented for 1) the operation of the deluge systems in the Control Room and, 2) for managing firewater usage, were in place and adequate. d) Ethylene Oxide Continuous Plant, Croda-Atlas Point. - On or about November 25, 2018, the employer failed to assure that written [HA-O3] procedures were developed and implemented which would enable connection to other firewater make-up sources, such as to Suez water, in order to maximize available water supply during an emergency release. e) Ethylene Oxide Continuous Plant, Croda-Atlas Point. - On or about November 25, 2018, the employer failed to assure that written [HA-O4] procedures were developed and implemented for operating the fire pumps and fire water tank at the Powerhouse. The hazardous conditions listed in the above instances exposed employees to toxic, fire, and explosion hazards posed by ethylene oxide.