Text For Citation: 03 Item/Group: 010 Hazard: REFINERY

29 CFR 1910.119(e)(5) The employer shall establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions. A. The employer did not establish a system to promptly address the PHA team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; and develop a written schedule of when these actions are to be completed. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. During review of the #1 Crude 2005 PHA, 215 recommendations were identified, yet no documentation as to the resolution status of these recommendations was available. In addition, from a review of the 1998 #1 Crude Unit PHA, it appears that 207 of the 215 #1 Crude 2005 PHA recommendations were produced during the 1998 process hazard review and just carried over. By not establishing a system to promptly address findings and recommendations, developing a written schedule, tracking status, and ensuring completion, the employer did not ensure recommendations were resolved as required by the standard. By not promptly addressing findings and recommendations, employees can be exposed to hazardous situations that can lead to serious injury or death. This may be a system-wide occurrence that requires evaluation of all PHA findings and recommendations for all covered processes throughout the facility. B. The employer did not establish a system to promptly address the PHA team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; and develop a written schedule of when these actions are to be completed. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. During review of the 2003-2004 MDDW-HDS PHA, the PHA includes 85 recommendations of which 36 indicate that they have been resolved. The 2009 MDDW PHA conducted during four meetings held between 6/3/09 and 8/5/09 did not document the status of the unresolved PHA recommendations from the 2003-2004 MDDW-HDS PHA. By not establishing a system to promptly address findings and recommendations, developing a written schedule, tracking status, and ensuring completion, the employer did not ensure recommendations were resolved as required by the standard. By not promptly addressing findings and recommendations, employees can be exposed to hazardous situations that can lead to serious injury or death. This may be a system-wide occurrence that requires evaluation of all PHA findings and recommendations for all covered processes throughout the facility. C. The employer did not establish a system to promptly address the PHA team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions assoon as possible; and develop a written schedule of when these actions are to be completed. This violation was identified during inspections of the facility from November 2009 to March 2010, Silver Eagle Refining Inc., 2355 South 1100 West, Woods Cross, UT, 84087. During review of the 2004 Reformer PHA, no documentation regarding the status of 26 of 33 recommendations was produced. Table 3: Analysis Recommendations lists 33 recommendations, with only one recommendation, # 10, indicating that it had been completed on 2/9/06. Three other recommendations indicate that they are resolved however no date of resolution is recorded. Three recommendations state under the "status" column, the word-"engineering" with no completion date recorded. Of the remaining 26 recommendations, there is no documentation to indicate that these items are being addressed. The May 20, 2009 process hazard analysis for the Reformer Unit does not include any documentation regarding the updated status of the 2004 recommendations. By not establishing a system to promptly address findings and recommendations, developing a written schedule, tracking status, and ensuring completion, the employer did not ensure recommendations were resolved as required by the standard. By not promptly addressing findings and recommendations, employees can be exposed to hazardous situations that can lead to serious injury or death. This may be a system-wide occurrence that requires evaluation of all PHA findings and recommendations for all covered processes throughout the facility.