Text For Citation: 01 Item/Group: 012 Hazard:

29 CFR 1910.119(e)(3): The process hazard analysis did not address: 29 CFR 1910.119(e)(3)(vi):Human factors; a. On or about and prior to April 8, 2021, for the PHA Revalidation, PHA High Temp Review 2015; the Human Factors node WHAT-IF question "Kettle discharge valves and lines" (Line 101) failed to address the human factor of "valve misalignment." Valve misalignment during kettle transfer of resin batches to Scale Tanks in the covered process can result in employee exposure to spills, leaks and atmospheric venting of highly hazardous chemicals and can result in catastrophic release of highly hazardous chemicals from the covered process. b. On or about and prior to April 8, 2021, for the PHA Revalidation, PHA High Temp Review 2015; for the Transfer into Scale Tanks node the WHAT-IF question "Transfer line is plugged from kettle to scale tank" (Line 10) failed to consider the human factor of "valve misalignment." Valve misalignment during kettle transfer of resin batches to Scale Tanks in the covered process can result in employee exposure to spills, leaks and atmospheric venting of highly hazardous chemicals and can result in catastrophic release of highly hazardous chemicals from the covered process.