Text For Citation: 01 Item/Group: 014 Hazard:

29 CFR 1910.119(i)(2)(iii): The pre-startup safety review did not confirm that for new facilities, a process hazard analysis (PHA) was completed before startup; a) Ethylene Oxide Continuous Plant, Croda-Atlas Point. - On or about November 25, 2018, the employer failed to perform a final process hazard analysis to ensure that all hazards were identified, evaluated and controlled before startup. The PHA update in 2016 did not identify process hazards such as how the firewater system did not take into account the flow from multiple users when designing the system for the maximum firewater demand. In addition, the DCS graphical interface for the firewater deluge system was difficult to understand resulting in the incorrect deluge system being activated, the control building was not designed to prevent toxic vapor ingress, and the nitrogen purge system for the 430 EO Purification Column could not be accessed during an EO release, resulting in employee exposure to ethylene oxide.