Text For Citation: 02 Item/Group: 001 Hazard:

29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process: On or about October 10, 2023, and at times prior thereto, the employer failed to develop and verify accurate piping and instrument diagrams (P&IDs) and did not represent the equipment in the aerosol filling process. The P&IDs were mislabeled in that tag numbers of equipment did not match the P&ID drawings and the P&ID legends for the equipment in the tank farm, the gashouse, and the manifold system. During the walk around, CSHO verified the P&ID drawings and the P&ID legends with the actual as-built layout, and observed the following deficiencies at the following instances: a) The equipment identified in the tank farm (Tank 06) P&ID drawing and legend (P&ID 01- North Pumps Skid, Revision 1, Date 5/3/2021) as numbers FV 37 (Globe Valve, 1" Fisher (1000 WOG)), PSV 41A (2" auto PSV (SP=185 psi)), and PSV 41B (2" auto PSV (SP=185 psi)), are not tagged. The as-built field setup had missing valve ID tags when compared to the P&ID for valves FV 37, PSV 41A, and PSV 41B. The P&ID drawing and the legend use a tagging system with numbers to identify the equipment for references in the Process Safety Information, Process Hazard Analysis, SOP, Mechanical Integrity testing and inspection, preventive maintenance, Training materials, Pre-Startup Safety Review, and Compliance Audits. b) The equipment identified in the tank farm (Tank 06) P&ID drawing and legend (P&ID 01- North Pumps Skid, Revision 1, Date 5/3/2021) as numbers FV 37 (Globe Valve, 1" Fisher (1000 WOG)). The P&ID legend identified the FV 37 valve as a Globe Valve, but the P&ID drawing identified it as a Right-Angle Valve. The legend indicated that there was a globe-type valve installed in the system, but the valve on the P&ID drawing was a right-angle valve. c) The equipment identified in the tank farm (Tank 07) P&ID drawing and legend (P&ID 02- South Pumps Skid, Revision 1, Date 5/5/2021) as numbers EID 21D (1.5" SS Braided Flexible Line w/union), (Tank 12) LG 38A (Tank Volume Guage (5-95%)), (Tank 08) LG 44B (Volume Guage (5-95%)), and (Tank 08) FV 45 (Globe Valve, 1" Rego TA7507A (400 WOG)) are not tagged. The as-built field setup had missing valve ID tags when compared to the P&ID for valves EID 21D, LG 38A, LG 44B, and FV 45. The P&ID drawing and the legend use a tagging system with numbers to identify the equipment. d) The equipment identified in the tank farm (Tank 07) P&ID drawing and legend (P&ID 02- South Pumps Skid, Revision 1, Date 5/5/2021) as numbers FV 31A (Valve, 3-Way Squibb-Taylor with 2" auto PSV (SP=250 psi)). The tags on the Tank 07 did not match the legend and the P&ID drawing. The P&ID drawing and legend both identified the pressure safety valve as FV 31A, but the valve in the tank farm identified it as FV 32. The South Pumps Skid P&ID and legend indicated that tag number FV 31A is a pressure safety valve but there was a pressure safety valve that was tagged number FV 32 in the same place and no valves tagged number FV 31A. e) The equipment identified in the tank farm (Tank 07) P&ID drawing and legend (P&ID 02- South Pumps Skid, Revision 1, Date 5/5/2021) as numbers FV 31B (Valve, 3-Way Squibb-Taylor with 2" auto PSV (SP=250 psi)). The tags on the Tank 07 did not match the legend and the P&IDs. The P&ID drawing and legend both identified the pressure safety valve as FV 31B, but the valve in the tank farm identified it as FV 31. f) The equipment identified in the tank farm (Tank 12) P&ID drawing and legend (P&ID 02- South Pumps Skid, Revision 1, Date 5/5/2021) as numbers FV 42A (Valve, 3-Way Squibb-Taylor with 2" auto PSV (SP=250 psi)). The tags on the Tank 12 did not match the legend and the P&IDs. The P&ID drawing and legend both identified the pressure safety valve as FV 42A, but the valve in the tank farm identified it as FV 42. g) The equipment identified in the tank farm (Tank 12) P&ID drawing and legend (P&ID 02- South Pumps Skid, Revision 1, Date 5/5/2021) as numbers FV 42B (Valve, 3-Way Squibb-Taylor with 2" auto PSV (SP=250 psi)). The tags on the Tank 12 did not match the legend and the P&IDs. The P&ID drawing and legend both identified the pressure safety valve as FV 42B, but the valve in the tank farm identified it as FV 41. h) The equipment identified in the tank farm (Tank 08) P&ID drawing and legend (P&ID 02- South Pumps Skid, Revision 1, Date 5/5/2021) as numbers PI 44A (Pressure Gauge (0-300 psi)). The tags on the Tank 08 did not match the legend and the P&IDs. The P&ID drawing and legend both identified the pressure indicator as PI 44A, but the valve in the tank farm identified it as FV 44. i) The equipment identified in the Aerosol Propellant System (by pipe P03-008C1-1.5"80) P&ID drawing and legend (P&ID 03- NW Corner of Gas House, Revision 1, Date 6/15/2021) as numbers FV 114 (Globe Valve, 1.0" Rego, 5O5A (400 WOG)), and EID 121 (1" Flex Line, Steel Braided). The tags on the Aerosol Propellant System did not match the legend and the P&IDs. The P&ID drawing and legend both identified the globe valve as FV 114 and the Flex Line EID 121, but the tags in the as-built system identified them in reverse order, they switch place with each other, they are not matching, they mislabeled. They had all of the labels on these switched around. (Valve number FV 114 of the Aerosol Propellant System is identified in the P&ID as a Globe Valve but the Aerosol Propellant System has a 1" Flex Line, Steel Braided with the tag number FV 114, and vice versa the 1" Flex Line EID 121 of the Aerosol Propellant System is identified in the P&ID as a 1" Flex Line, but the Aerosol Propellant System has a Globe Valve FV 114 with the tag number EID 121.) j) The equipment identified in the Aerosol Propellant System (by pipe P03-008C1-1.5"80) P&ID drawing and legend (P&ID 03- NW Corner of Gas House, Revision 1, Date 6/15/2021) as numbers FV 116 (Globe Valve, 1.0" Rego, 5O5A (400 WOG)), and EID 118 (1" Flex Line, Steel Braided). The tags on the Aerosol Propellant System did not match the legend and the P&IDs. The P&ID drawing and legend both identified the globe valve as FV 116 and the Flex Line EID 118, but the tags in the as-built system identified them as reverse order, they switch place with each other, they are not matching, they mislabeled. They had all of the labels on these switched around. k) The equipment identified in the Aerosol Propellant System (by pipe P02-013C1-1.0"80) P&ID drawing and legend (P&ID 03- NW Corner of Gas House, Revision 1, Date 6/15/2021) as numbers ES 186 (Electrical Switch (Push Button) E-Stop), and ES 187 (Electrical Switch (Push Button) Reset FV-119 and FV-120). The as-built field setup outside of gas house building had missing valve ID tags when compared to the P&ID for valves ES 186, and ES 187. The as-built setup did not show these Electrical Switch Push Buttons labeled. The P&ID drawing and the legend use a tagging system with numbers to identify the equipment. l) The equipment identified in the Aerosol Propellant System Manifold (by pipe P04-002C1-0.5"80) P&ID drawing and legend (P&ID 04- Manifold, Revision 2, Date 6/21/2021) as number FV 168 (Needle Valve, 1/2" K-F (400 psi)) is not tagged. The as-built field setup had missing valve ID tags when compared to the P&ID for valve FV 168. The P&ID drawing and the legend use a tagging system with numbers to identify the equipment. m) The equipment identified in the Aerosol Propellant System Gas House Equipment (by pipe P05-006C1-0.5"80 and vacuum V05-013C1-2.5"80) P&ID drawing and legend (P&ID 05- Gas House Equipment, Revision 1, Date 7/6/2021) as numbers FV 208 Self Operating Release Valve, ES 211 (Push Button Controls for High Pressure Pump System), and ES 217 (Push Button E-Stop) are not tagged. The as-built field setup had missing valve ID tags when compared to the P&ID for valves FV 208, ES 211, and ES 217. The P&ID drawing and the legend use a tagging system with numbers to identify the equipment. n) The equipment identified in the Aerosol Propellant System Gas House Equipment (by pipe P05-006C1-0.5"80) P&ID drawing (P&ID 05- Gas House Equipment, Revision 1, Date 7/6/2021) as number FV 208 Self Operating Release Valve and was verified in the as-built setup in the field but FV 208 was not identified in the legend to illustrate the tag number, drawing number, the function, and the description of that valve. The legend listed 207 to 209 but no 208 in between these two-tag number identification. Employees engaged in operating, processing, inspecting, testing and preventive maintenance of the aerosol filling operations and processes were potentially exposed to fire and explosion hazards from the release of flammable liquids and gases which could result in serious injury or death. The Fuller Industries, Inc. was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.119(d)(3)(i)(B), which was contained in OSHA inspection number 1498785, citation number 1, item number 8 and was affirmed as a final order on 04-29-2021, with respect to a workplace located at 15 SW 40 Avenue GREAT BEND, KS 67530.