Text For Citation: 01 Item/Group: 033 Hazard:

29 CFR 1910.119(f)(1)(iii)(B): The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements: Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment: For the phosphites plant building #27, the employer did not provide specific written procedures to ensure employees would not be exposed to workplace related hazards, including but not limited to: a. PHOS SOPM 100, Personal Chemical Safety Precautions was not specific to the type of personal protective equipment (PPE) required and did not accurately reflect information ascertained from the PPE hazard assessment. b. PHOS SOPM 152, Power Failure Emergency Shutdown was not specific to the type of PPE required and did not accurately reflect information ascertained from the PPE hazard assessment. c. PHOS SOPM 201, Unloading Trucks Raw Materials was not specific to the type of PPE required and did not accurately reflect information ascertained from the PPE hazard assessment. d. PHOS SOPM 205, Unloading PCL3 From Railcars was not specific to the type of PPE required and did not accurately reflect information ascertained from the PPE hazard assessment. e. PHOS SOPM 206, Changing Filter for 44Rx and 75Rx was not specific to the type of PPE required and did not accurately reflect information ascertained from the PPE hazard assessment. f. PHOS SOPM 207, Replacing Dirty TCP in 508T/510T was not specific to the type of PPE required and did not accurately reflect information ascertained from the PPE hazard assessment. g. PHOS SOPM 295, Charging Used (Distilled) Phenol back to Reactors was not specific to the type of PPE required and did not accurately reflect information ascertained from the PPE hazard assessment. h. PHOS SOPM 297, Trouble-Shooting in Process Batches was not specific to the type of PPE required and did not accurately reflect information ascertained from the PPE hazard assessment. i. PHOS SOPM 305, Unloading Phosphorus Trichloride (PCL3) from ISO Containers and Tank Trucks was not specific to the type of PPE required and did not accurately reflect information ascertained from the PPE hazard assessment. j. PHOS SOPM 402, Plate and Frame Filter Operation was not specific to the type of PPE required and did not accurately reflect information ascertained from the PPE hazard assessment. k. PHOS SOPM 405, Carbon (Acid) Tower Operation was not specific to the type of PPE required and did not accurately reflect information ascertained from the PPE hazard assessment. l. PHOS SOPM 407, Carbon Tower Operation was not specific to the type of PPE required and did not accurately reflect information ascertained from the PPE hazard assessment. m. PHOS SOPM 409, 9228 Production in 36R (PCL3 Process) was not specific to the type of PPE required and did not accurately reflect information ascertained from the PPE hazard assessment. n. PHOS SOPM 410, 9228 Production in 32R was not specific to the type of PPE required and did not accurately reflect information ascertained from the PPE hazard assessment. For the Chlorination department 1C building #17, the employer did not provide specific written procedures to ensure employees would not be exposed to workplace related hazards, including but not limited to: o. 1C-10, Personal Chemical Safety Precautions was not specific to the type of PPE required and did not accurately reflect information ascertained from the PPE hazard assessment. p. 1C-18, 49 Reactor Shutdown Procedure did not address PPE required for leaks. q. 1C-19, 63 Reactor Shutdown Procedure did not address PPE required for leaks. r. 1C-26, 20 Reactor Shutdown Procedure did not address PPE required for leaks. s. 1C-27, 18 & 19 Reactors Shutdown Procedure did not address PPE required for leaks. t. 1C-31, Unloading Raw Material-Tank Trucks does not address PPE required for leaks. For the Chlorination department 1P building #6, the employer did not provide specific written procedures to ensure employees would not be exposed to workplace related hazards, including but not limited to: u. 1P-01, Personal Chemical Safety Precautions was not specific to the type of PPE required and did not accurately reflect information ascertained from the PPE hazard assessment. v. 1P-03B, #1 and 2 Reactor Shutdown Procedures did not address PPE. w. 1P-03C, #4 Operating Procedure did not address PPE. x. 1P-03D, #5 Reactor Operating Procedure did not address PPE. y. 1P-03F, #45 Reactor Operating Procedure did not address PPE. z. 1P-05, Emergency Shutdown Procedures did not address PPE. aa. 1P-08, Bromine Unloading did not address PPE. bb. 1P-10, Unloading Caustic-Tank Trucks did not address PPE.