OSHA has cited a chemical plant with 12 serious, one repeat and one other-than-serious violations for exposing workers to multiple safety hazards while producing organic chemicals. OSHA's Houston North Area Office initiated an inspection of the plant in January after receiving an employee complaint, and later expanded the inspection under the agency's process safety management national emphasis program for preventing or minimizing the catastrophic release of toxic, reactive, flammable or explosive chemicals. Proposed penalties total $117,100.

PLEASE NOTE the references to "Car Seal Program" in association with ASME Section VIII and ISA84 as the RAGAGEP for the design and maintenance of their instrumentation!

The serious violations include:

1910.119(d)(3)(i)(D) Relief system design and design basis ($7K)

• the relief system design basis did not included back pressure calculations and verifications
• no design calculations for the worst case scenario(s)
• no pressure drop calculations

1910.119(d)(3)(i)(H) Safety systems (e.g. interlocks, detection or suppression systems) ($5.5K)

• no specific PSI data on items that were called out as "safeguards" in a 2007 PHA. Instrument Loop drawings, Functional test records, recommended PM schedules, set-points were not developed for 2 specific safeguards.

1910.119(d)(3)(ii) The employer shall document that equipment complies with recognized and generally accepted good engineering practices. ($7K)

• Interlocks and alarms did not meet any type of RAGAGEP, such as but not limited to ISA-84. All of the instruments listed in the citation were pulled from the 2007 PHA Safeguards!
• Relief Valve discharge points did not meet RAGAGEP such as ASME Division I, Section VIII, UG-135(f)
• Car Seals on intervening valves did not meet RAGAGEP such as ASME Division I, Section VIII, UG-135(d)  

CLICK HERE to read my Car Seal articles referencing ASME Section VIII Appendix M

1910.119(e)(3)(iii) Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.($7K)

• PHA did not address the engineering and administrative controls applicable to the hazards and their interrelationship
• A flare dump valve was listed as a safeguard in a PHA, but the intervening valves on both sides of the dump valve were not in the car seal program
• Block valves around an interlock could be closed and thus make both the alarm and interlock INOPERABLE were not car sealed OPEN

1910.119(e)(3)(iv) Consequences of failure of engineering and administrative controls ($7K)

• PHA did not address the consequences of failure of engineering and administrative controls. 
• OSHA calls out about 10 valves that were in their improper position or missing their car seals that were not covered in the PHA as to what happens if these valves are deviated to their unsafe position through the failure of the car seal program.

1910.119(f)(1) The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements. ($???)

• No operating procedures for the administrative control of the use of intervening block valves for relief devices. OSHA is requiring them to implement a car-seal program that meets ASME Division I, Section VIII, UG-135(d) and Appendix M.

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. ($7K)

• No system established to ensure that PHA recommendations are resolved in a timely manner and resolution is documented.
• Interestingly enough, OSHA went back as far as the 1994 PHA, 1999 PHA, 2002 PHA to find items still not addressed.

1910.119(e)(7) Employers shall retain process hazards analyses and updates or revalidations for each process covered by this section, as well as the documented resolution of recommendations described in paragraph (e)(5) of this section for the life of the process. ($7K)

• Facility did not maintain the PHA's, updates, and revalidations, for each covered process; as well as the documented resolutions for the life of the process.

1910.119(f)(1)(iv) Safety systems and their functions ($7K)

• The SOPs did not contain information on the safety systems listed in the 2007 PHA as safeguards.
• Specifically called some Hi-Hi pressure/temperature/motor amp alarms/interlocks.

1910.119(j)(2) Written procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment. ($7K)

• No written MI procedures for intervening block valves on relief systems
• No written MI procedures for inspection and testing of protective instruments as per the company's MI Program Section VII
• Rupture Disc leaking by identified during audits not addressed

NOTE: it appears from some of the OSHA comments that the company has stated in a high level document that they will use ISA84 for their instruments

1910.119(j)(4)(iv) The employer shall document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test. ($5.5K)

• MI records did not include the date of the test/inspection, description of the test/inspection, or the results of the test/inspection
• OSHA specifically calls out some pressure and temperature indicators and compressor shutdown interlocks

1910.119(j)(5) Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation. ($7K)

• Rupture Discs before relief valves were found to be blown or leaking by and impacting the integrity of the relief valve

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. ($7K)

• OSHA found items from a 2008 Audit that had not been addressed

The repeat violation is for failing to review and certify operating procedures on an annual basis to ensure that current practices are being followed.

1910.119(f)(3) The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer shall certify annually that these operating procedures are current and accurate. (REPEAT for $35K)

• Start-up and Shutdown SOPs were not being revised to reflect current operating practices
• the REPEAT comes from this same plant, exactly one year prior to this inspection they were cited for not updating procedures to reflect current practices

The other-than-serious violation is for failing to develop safe work practices to control entrance into covered processes. 

1910.119(f)(4) The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees. ($1.1K)

• Fire Extinguisher inspection contractors were not required to sign in and out of each process unit, only the main control room.
• Other company "support personnel" such as the Operations Managers, Production Super, and process engineer were not required to sign in and out of process units

Click Here for the actual OSHA citations.