Text For Citation: 01 Item/Group: 023 Hazard:

29 CFR 1910.119(e)(3)(i): Process hazard analysis. The process hazard analysis shall address: The hazards of the process: Process hazards were not addressed during process hazard analysis, such as but not limited to: a. Phosphites department 2008 PHA: The employer did not identify, evaluate and control polymerization reactions of poly-available alcohols used in processes when it conducted the PHA. b. Phosphites department 2008 PHA: The employer did not identify, evaluate and control water reactivity of phosphites chemicals (DP10, etc.) and PCl3 when it conducted the PHA. c. Phosphites department 32R 9228 process PHA: The employer did not fully evaluate and control equipment failure as a mode for fire or as an ignition source, such as with a high temperature in a pump boiling xylene and being deemed as no hazardous consequence. d. Phosphites department PHAs (32R/36R 9228 and 2008 revalidation): The employer did not fully identify, evaluate and control the hazards associated with nitrogen as a widely used process chemical that poses the ability to displace oxygen, as a potential agent for creating an overpressure in a vessel and the potential loss of nitrogen when used to protect process chemicals from water infiltration. e. Phosphites department 32R 9228 process PHA: The employer did not fully identify, evaluate and control the hazards associated with elevated temperature. When dealing with the cause of overheating a reactor, the outcome of no hazardous consequence and operational and quality issues only were associated with vigorous boiling of reactor contents with additional internal pressure. The PHA team did not fully identify or control the hazard.