Text For Citation: 01 Item/Group: 018 Hazard: CHEMICAL

29 CFR 1910.119(o)(1): The employer did not certify that they had evaluated compliance with the provisions of 29 CFR 1910.119 at least every three years to verify that the procedures and practices developed under this standard were adequate and were being followed: a) Facility Wide - The ConocoPhillips audit process is designed to satisfy NJ TCPA requirements and does not necessarily meet OSHA compliance audit specifications. The following inconsistencies have been noted with the employer's compliance audit: 1- Accuracy of P&IDs was not adequately addressed during the compliance audit with numerous deficiencies noted to include but not limited to a missing critical flag for RL028 on TK12 (ABW), valves not car sealed for D118 & E122 (2PF), unmarked unit equipment at 2PF (E103, E106), safety valve on J101 marked with wrong temperature and pressure (2PF), 2- The audit did not adequately cover a review of hot work permits, 3- The audit did not adequately cover operating procedures with inaccuracies noted in reactor regeneration procedures Section 2.5.1.05 Action 7 Step 13, 4- The auditing process for review of procedures and the accuracy of completeness for process safety information is assigned to supervisors (first line/shift operations) and in effect becomes a self audit. A person familiar with the process but who is independent of the management system has not been designated to review procedures and accuracy of the process safety information which is not consistent with good industry practice (Section 4.2.1, Guidelines for Implementing Process Safety Management Systems, Center for Chemical Process Safety, 1994). Conditions noted on or about 03/14/08.s