Text For Citation: 01 Item/Group: 076 Hazard:

29 CFR 1910.119(o)(4): The employer shall promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected: a. For the May 2011 compliance audit, the employer had not corrected audit finding PSI-1 (1910.119(d)(1)) regarding engineering specifications for guidelines on corrosivity and materials of construction. Process safety information (PSI) in these areas had not been developed. The employer did not have fully developed guidelines on corrosivity for process equipment and materials of construction information, such as piping specifications had not been documented. b. For the May 2011 compliance audit, the employer had not corrected audit finding PSI-2 (1910.119(d)(1)) regarding the hazardous effects of inadvertent mixing for process chemicals. Prior to the initiation of this inspection, the employer had not developed a guideline for inadvertent mixing as part of process safety information to correct this audit finding. c. For the May 2011 compliance audit, the employer had not corrected audit finding PSI-3 (1910.119(d)(2)) regarding updating information pertaining to technology of the processes. The employer had not reviewed and then updated process safety information as a corrective action for this audit finding. d. For the May 2011 compliance audit, the employer had not corrected audit finding PSI-4 (1910.119(d)(3)) regarding compiling process safety information for materials of construction, electrical classification, rupture disks and pressure relief valves. Materials of construction information were not in place, electrical classification information was not complete and ruptured disk/pressure relief device information is also not complete. e. For the May 2011 compliance audit, the employer had not corrected audit finding PSI-5 (1910.119(d)(3)) regarding safety systems. The employer had not compiled process safety information for safety systems such as alarms, interlocks and permissives. f. For the May 2011 compliance audit, the employer had not corrected audit finding PSI-6 (1910.119(d)(3)(ii)) regarding recognized and generally accepted good engineering practices (RAGAGEP) documentation for equipment. The employer had not evaluated equipment and compiled information for equipment RAGAGEP compliance. g. For the May 2011 compliance audit, the employer had not corrected audit finding OP-1 (1910.119(f)(1)) regarding resolution of operating procedure content. Written operating procedures were not compliant. h. For the May 2011 compliance audit, the employer had not corrected audit finding OP-2 (1910.119(f)(3)) regarding certification of operating procedures. Operating procedures were not reviewed, then certified as current and accurate. i. For the May 2011 compliance audit, the employer had not corrected audit finding PSSR-2 (1910.119(i)) regarding tracking and documenting action item completion for pre-startup safety review (PSSR). PSSR action items were not tracked, completed and documented by the employer. j. For the May 2011 compliance audit, the employer had not corrected audit finding MI-1 (1910.119(j)) regarding identifying all equipment to be included in the mechanical integrity program. The employer had not completed the documentation of a list of all equipment to be included in the mechanical integrity program, also known as the critical equipment list. k. For the May 2011 compliance audit, the employer had not corrected audit finding MI-2 (1910.119(j)(2)) regarding establishing mechanical integrity programs. The employer had not implemented effective mechanical integrity programs. l. For the May 2011 compliance audit, the employer had not corrected audit finding MI-3 (1910.119(j)(4)) regarding inspection and testing. The employer had equipment operating without any inspection and testing, with overdue inspection and testing and with inspection and testing that did not meet RAGAGEP. m. For the May 2011 compliance audit, the employer had not corrected audit finding MI-4 (1910.119(j)(5)) regarding inspection and testing reported deficiency corrective action documentation. The employer had equipment operating with noted deficiencies that had not been adequately resolved, corrected and documented. n. For the May 2011 compliance audit, the employer had not corrected audit finding MOC-4 (1910.119(l)(5)) regarding management of change (MOC) process safety information updates and procedure updates. Written operating procedure updates were not comprehensively occurring following MOC processes and reviews. o. For the May 2011 compliance audit, the employer had not corrected audit finding II-1 (1910.119(m)(5)) regarding a system addressing investigation findings corrective actions. Incident investigation findings were not corrected and documented for completion. p. For the May 2011 compliance audit, the employer had not corrected audit finding CA-2 (1910.119(o)(4)) regarding resolving 2007 compliance audit findings. The 2007 compliance audit findings were not completely corrected. q. For the May 2011 compliance audit, the employer had not corrected audit finding PHA-2 (1910.119(e)(5)) regarding completion of outstanding process hazard analysis (PHA) recommendations from 2008. PHA recommendations from 2008 were not completely resolved. r. For the December 2007 compliance audit, the employer had not corrected finding 8 (1910.119(m)(5)) regarding a system addressing investigation findings corrective actions. Incident investigation findings were not corrected and documented for completion. s. For the December 2007 compliance audit, the employer had not corrected finding 17 (1910.119(l)(5)) regarding updating management of change process safety information updates. Process safety information updates were not comprehensively occurring following MOC processes and review. t. For the December 2007 compliance audit, the employer had not corrected finding 18 (1910.119(f)(1)(i-ii)) regarding operating procedures containing safe operating limits, consequence of deviation and corrective actions for deviations. Operating procedures currently did not contain this information. u. For the May 2007 compliance audit, the employer had not corrected audit finding 19 (1910.119(f)(3)) regarding certification of operating procedures. Operating procedures were not reviewed, then certified as current and accurate. v. For the May 2007 compliance audit, the employer had not corrected audit finding 23 (1910.119(e)(5)) regarding process hazard analysis (PHA) recommendation timely completion and proper documentation. Recommendations for 2008 PHA items were unresolved. w. For the May 2007 compliance audit, the employer had not corrected audit finding 26 (1910.119(i)(2) and (l)(5)) regarding documentation and completion of PSSR/MOC action items. PSSR action items were not adequately tracked to completion and some action items were unresolved. x. For the May 2007 compliance audit, the employer had not corrected audit findings 38 and 39 (1910.119(g)(1)) regarding operator and maintenance training. Operator and maintenance employee training programs were not compliant. y. For the 2007 compliance audit, the employer had not corrected audit finding 41 (1910.119(g)(2)) regarding operator refresher training performance. Operator refresher training was not performed. z. For the 2007 compliance audit, the employer had not corrected audit finding 43 (1910.119(j)(1)(i-vi)) regarding written vessel and tank inspection program for scheduled inspections. Inspections for all vessels and tanks were not adequate, timely and performed to RAGAGEP. aa. For the 2007 compliance audit, the employer had not corrected audit finding 44 (1910.119(j)(1)(i-vi)) regarding written piping circuit and flexible hose inspection program. This program did not exist and the only piping circuit testing and inspection was not performed to RAGAGEP. bb. For the 2007 compliance audit, the employer had not corrected finding 45 (1910.119(j)(1)(i-vi)) regarding relief device procedure development, completion of overdue inspections and program implementation. This program was inadequate, inspections were not properly documented, devices were not properly installed to the design basis and procedures for establishing predictive data were not established. cc. For the 2007 compliance audit, the employer had not corrected finding 46 (1910.119(j)(1)(i-vi)) regarding emergency shutdown systems and area monitors. Procedures for inspection, maintenance and deficiency resolution were not in place for this type of equipment. dd. For the 2007 compliance audit, the employer had not corrected finding 47 (1910.119(j)(1)(i-vi)) regarding critical equipment and instrumentation list, to include development of a preventive maintenance schedule and PSI development. The list, schedule and PSI had not been developed. ee. For the 2007 compliance audit, the employer had not corrected finding 49 (1910.119(j)(3)) regarding maintenance training. The employer did not provide a documented maintenance training program for mechanical integrity and PSM requirements. ff. For the 2007 compliance audit, the employer had not corrected finding 50 (1910.119(j)(4)(ii)) regarding qualified contractors performing code inspections. Qualified piping inspections had not occurred to address this finding. gg. For the 2007 compliance audit, the employer had not corrected finding 51 (1910.119(j)(3)(iv)) regarding work order use for future predictive maintenance activities. The work order system had not improved and predictive maintenance programs did not exist. hh. For the 2007 compliance audit, the employer had not corrected finding 52 (1910.119(j)(5)) regarding equipment deficiency correction and documentation procedures. The mechanical integrity program was deficient in this area. ii. For the 2007 compliance audit, the employer had not corrected finding 53 (1910.119(j)(6)(ii)) regarding parts and equipment quality assurance. Although there were checklist items for MOC and PSSR forms, the facility had no functional quality assurance program in place. jj. For the 2007 compliance audit, the employer had not corrected finding 54 (1910.119(d)(3)(ii)) regarding development of a critical equipment list for use in documenting design code/basis information and documenting RAGAGEP compliance. The equipment list had not been developed and equipment file information did not provide RAGAGEP compliance. kk. For the 2007 compliance audit, the employer had not corrected findings 56 and 57 (1910.119(d)(3)) regarding PSI for instrument specifications, pipe specifications, process & instrumentation diagrams, relief system design basis, design codes and standards and safety systems were not corrected. PSI was not compiled and completely documented for these areas.