OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

Subject: Changes to the Regulatory and General Industry Standard Alleged Violation Elements (SAVEs) Manual

A. PURPOSE. This instruction transmits revised and new pages to the Regulatory and General Industry SAVEs Manual for Process Safety Management of Highly Hazardous Chemicals; Explosives and Blasting Agents.

B. SCOPE. This instruction applies OSHA-wide.

C. ACTION. Regional Administrators and Area Directors shall ensure that all compliance personnel:

1. Make the following page changes to the Regulatory and General Industry (SAVES) Manual:

REMOVE PAGES INSERT PAGES

143-146 143 through 144 145 through 146

2. File a copy of this transmittal sheet behind OSHA Instruction CPL 2.35 CH-21 in the appropriate OSHA Directive System binder.

D. BACKGROUND. Final rule and regulations for 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals; Explosives and Blasting Agents, were published in the FEDERAL REGISTER, Vol.57, No.36, on February 24, 1992.

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

E. STATE PLAN STATES. Regional Administrators shall advise State designees of the action required by this instruction and encourage their participation in the SAVEs program.

Roger A. Clark, Director Directorate of Compliance Programs

DISTRIBUTION: National, Regional, and Area Offices Compliance Officers State Designees Area Office Clericals 11(c)/405 Programs NIOSH Regional Program Directors

2

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.109(i)(3)(ii)(C): Ammonium nitrate was stacked closer than 36 inches below the roof or supporting and spreader beams overhead:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATIONS(S) AND/OR CONDITIONS)(DESCRIBE HAZARD(S) WHERE NECESSARY)

OPTION 1 2 29 CFR 1910.109(i)(3)(ii)(D): Aisles(s) at least 3 feet wide were not provided to separate piles of ammonium nitrate:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATION(S) AND/OR CONDITIONS)(DESCRIBE HAZARD(S) WHERE NECESSARY)

OPTION 2 3 29 CFR 1910.109(i)(3)(ii)(D): At least one service or main aisle, 4 feet or more in width, was not provided in ammonium nitrate storage area(s):

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATION(S) AND/OR CONDITIONS)(DESCRIBE HAZARD(S) WHERE NECESSARY)

4 29 CFR 1910.110(b)(6)(vi): Readily ignitable material was not removed within 10 feet of LP gas container(s):

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATION(S) AND/OR CONDITIONS)(DESCRIBE HAZARD(S) WHERE NECESSARY)

143

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.110(d)(10): Precautions were not taken to prevent damage to LP gas system(s) from vehicular traffic:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATION(S) AND/OR CONDITIONS)(DESCRIBE HAZARD(S) WHERE NECESSARY)

2 29 CFR 1910.110(e)(4)(iii): LP gas container(s) installed on internal combustion engine vehicles were not securely mounted to prevent jarring loose, slipping or rotating:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATION(S) AND/OR CONDITIONS)(DESCRIBE HAZARD(S) WHERE NECESSARY)

NOTE: See standard for exception(s) and/or additional requirements.

3 29 CFR 1910.110(f)(2)(i): LP gas container(s) in storage were not located so as to minimize exposure to excessive temperature rise, physical damage, or tampering by unauthorized persons:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATION(S) AND/OR CONDITIONS)(DESCRIBE HAZARD(S) WHERE NECESSARY)

NOTE: Applies to storage of containers awaiting use or resale.

143.1

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.110(f)(2)(ii): LP gas container(s) stored inside were located near or in area(s) normally used or intended for the safe exit of employees:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATION(S) AND/OR CONDITIONS)(DESCRIBE HAZARD(S) WHERE NECESSARY)

NOTE: Applies to storage of containers awaiting use or resale.

2 29 CFR 1910.110(f)(4)(i): The quantity of LP gas stored inside of building(s) exceeded 300 pounds:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATION(S) AND/OR CONDITIONS)(DESCRIBE HAZARD(S) WHERE NECESSARY)

NOTE: See standard for exception(s) and/or additional requirements.

3 29 CFR 1910.110(f)(6)(ii): LP gas container(s) stored outside of buildings were not in a suitable enclosure or otherwise protected against tampering:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATION(S) AND/OR CONDITIONS)(DESCRIBE HAZARD(S) WHERE NECESSARY)

NOTE: Applies to containers awaiting use or resale.

4 29 CFR 1910.110(f)(7): LP gas container storage location(s) were not provided with at least one approved portable fire extinguisher having a minimum rating of 8-B, C:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATION(S) AND/OR CONDITIONS)(DESCRIBE HAZARD(S) WHERE NECESSARY)

NOTE: See standard for exception(s) and/or additional requirements.

143.2

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.110(h)(12): Conspicuous signs prohibiting smoking were not posted within sight of customers served at LP gas dispensing areas:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATION(S) AND/OR CONDITIONS)(DESCRIBE HAZARD(S) WHERE NECESSARY)

OPTION 2 2 29 CFR 1910.110(h)(12): Motor(s) of vehicle(s) which were fueled with LP gas were not shut off during fueling operations:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATION(S) AND/OR CONDITIONS)(DESCRIBE HAZARD(S) WHERE NECESSARY)

3 29 CFR 1910.110(h)(14): LP gas service station(s) were not provided with at least one approved portable fire extinguisher having at least an 8-B, C rating:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATION(S) AND/OR CONDITIONS)(DESCRIBE HAZARD(S) WHERE NECESSARY)

4 29 CFR 1910.111(b)(10)(ii): Stationary only ammonia storage installation(s) did not have at least two suitable gas masks in readily accessible locations:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATION(S) AND/OR CONDITIONS)(DESCRIBE HAZARD(S) WHERE NECESSARY)

NOTE: This standard does not apply to Ammonia MFG. Plants or Refrigeration Plants where ammonia is used solely as a refrigant. See scope section under 29 CFR 1910.111.

144

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(c)(1): The employer did not develop a written plan of action regarding the implementation of the employee participation required by 29 CFR 1910.119:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 1 2 29 CFR 1910.119(c)(2): The employer did not consult with employees and their representative on the conduct and development of process hazards:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 2 3 29 CFR 1910.119(c)(2): The employer did not consult with employees and their representative on the development of elements of process safety management:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(c)(3): The employer did not provide to employees and their representatives access to process hazard analyses and to all other information required to be developed under 29 CFR 1910.119:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: TIME SCHEDULES FOR IMPLEMENTATION OF PARAGRAPHS (d) & (e) stated in 29 CFR 1910.119(e)(1)(i) through (v).

145

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(d): The employer did not develop a written compilation of process safety information on hazardous chemicals in the process, the technology of the process, and the equipment in the process before conducting the process hazard analysis:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: TIME SCHEDULES FOR IMPLEMENTATION OF PARAGRAPHS (d) & (e) stated in 29 CFR 1910.119(e)(1)(i) through (v).

2 29 CFR 1910.119(d)(1): Process safety information pertaining to the hazards of the highly hazardous chemicals in the process did not consist of the elements specified in 29 CFR 1910.119(d)(1)(i) through (vii):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(d)(1)(i): Process safety information pertaining to the hazards of the highly hazardous chemicals in the process did not contain the toxicity information:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(d)(1)(ii): Process safety information pertaining to the hazards of the highly hazardous chemicals in the process did not contain the permissible exposure limits:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

5 29 CFR 1910.119(d)(1)(iii): Process safety information pertaining to the hazards of the highly hazardous chemicals in the process did not contain the physical data information:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.1

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(d)(1)(iv): Process safety information pertaining to the hazards of the highly hazardous chemicals in the process did not contain the reactivity data information:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

2 29 CFR 1910.119(d)(1)(v): Process safety information pertaining to the hazards of the highly hazardous chemicals in the process did not contain the corrosivity data information:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(d)(1)(vi): Process safety information pertaining to the hazards of the highly hazardous chemicals in the process did not contain the thermal and chemical stability data:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(d)(1)(vii): Process safety information pertaining to the hazards of the highly hazardous chemicals in the process did not contain the hazardous effects of inadvertent mixing of different materials that could foreseeably occur:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: Material Safety Data Sheets meeting the requirements of 29 CFR 1910.1200(g) may be used to comply with this requirement to the extent they contain the information required by the subparagraph.

145.2

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(d)(2)(i): Process safety information pertaining to the technology of the process did not include the elements specified in 29 CFR 1910.119(d)(2)(i)(A) through (E):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

2 29 CFR 1910.119(d)(2)(i)(A): Process safety information pertaining to the technology of the process did not include a block flow diagram or simplified process flow diagram:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: See appendix B for examples of an acceptable type diagram.

3 29 CFR 1910.119(d)(2)(i)(B): Process safety information pertaining to the technology of the process did not include the process chemistry:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(d)(2)(i)(C): Process safety information pertaining to the technology of the process did not include the maximum intended inventory:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

5 29 CFR 1910.119(d)(2)(i)(D): Process-safety information pertaining to the technology of the process did not include the safe upper and lower limits for such items as temperatures, pressures, flows or compositions:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.3

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(d)(2)(i)(E): Process safety information pertaining to the technology of the process did not include an evaluation of the consequence of deviations, including those affecting the safety and health of employees:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

2 29 CFR 1910.119(d)(3)(i): Process safety information pertaining to the equipment in the process did not include the elements specified in 29 CFR 1910.119(d)(3)(i)(A) through (H):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(d)(3)(i)(A): Process safety information pertaining to the equipment in the process did not include the materials of construction:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(d)(3)(i)(B): Process safety information pertaining to the equipment in the process did not include the piping and instrument diagrams (P&ID's):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

5 29 CFR 1910.119(d)(3)(i)(C): Process safety information pertaining to the equipment in the process did not include the electrical classification:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.4

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(d)(3)(i)(D): Process safety information pertaining to the equipment in the process did not include the relief system design and design basis:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

2 29 CFR 1910.119(d)(3)(i)(E): Process safety information pertaining to the equipment in the process did not include the ventilation system design:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(d)(3)(i)(F): Process safety information pertaining to the equipment in the process did not include the design codes and standards employed:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR - CONDITIONS)

4 29 CFR 1910.119(d)(3)(i)(G): Process safety information pertaining to the equipment in the process did not include the material and energy balances for processes built after May 26, 1992:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

5 29 CFR 1910.119(d)(3)(i)(H): Process safety information pertaining to the equipment in the process did not include the safety systems (e.g. interlocks, detection or suppression systems):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.5

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(d)(3)(ii): The employer did not document that the equipment in the process complied with recognized and generally accepted good engineering practices:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

2 29 CFR 1910.119(d)(3)(iii): For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer did not determine and document that the equipment in the process was designed, maintained, inspected, tested, and operated in a safe manner:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 1 3 29 CFR 1910.119(e)(1): The employer did not perform an initial process hazard analysis (hazard evaluation) on processes covered by 29 CFR 1910.119:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 2 4 29 CFR 1910.119(e)(1): The process hazard analysis was not appropriate to the complexity of the process and did not identify, evaluate, and address the control of the hazards involved in the process:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.6

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 3 1 29 CFR 1910.119(e)(1): The employer did not determine and document the priority order for conducting process hazard analyses based on a rationale which included such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 4 2 29 CFR 1910.119(e)(1): The process hazard analysis was not conducted as soon as possible or in accordance with the schedule presented in 29 CFR 1910.119(e)(1)(i) through (e)(1)(v):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(e)(2): The employer did not use or did not use correctly one or more of the methodologies presented in 29 CFR 1910.119(e)(2)(i) through (vii) that were appropriate to determine and to evaluate the hazards of the process being analyzed:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

5 29 CFR 1910.119(e)(3)(ii): The process hazard analysis did not identify any previous incident which had a likely potential for catastrophic consequences in the workplace:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.7

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(e)(3)(iii): The process hazard analysis did not address the engineering and administrative controls applicable to the hazards and their interrelationship, such as, appropriate application of detection methodologies to provide early warning of releases:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

2 29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not address the consequences of failure of engineering and administrative controls:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not address human factors:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

5 29 CFR 1910.119(e)(3)(vii): The process hazard analysis did not include a qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.8

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.119(e)(4): The process hazard analysis was not performed by a team with expertise in engineering and process operations:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 2 2 29 CFR 1910.119(e)(4): The team performing the process hazard analyses did not include at least one employee who had experience and knowledge specific to the process being evaluated:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 3 3 29 CFR 1910.119(e)(4): The team performing the process hazard analysis did not include at least one member who was knowledgeable in the specific process hazard analysis methodology being used:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 1 4 29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the process hazard analysis team's findings and recommendations:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 2 5 29 CFR 1910.119(e)(5): The employer did not establish a system to assure that the process hazard analysis team's recommendations are resolved in a timely manner and that the resolution is documented:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.9

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 3 1 29 CFR 1910.119(e)(5): The employer did not establish a system to document what actions are to be taken concerning the process hazard analysis team's recommendation:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 4 2 29 CFR 1910.119(e)(5): The employer did not establish a system to complete actions recommended by the process hazard analysis team as soon as possible:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 5 3 29 CFR 1910.119(e)(5): The employer did not develop a written schedule as to when the actions recommended by the process hazard analysis team are to be completed:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 6 4 29 CFR 1910.119(e)(5): The employer did not establish a system to communicate the actions to be taken, as a result of the process hazard analysis team's recommendations, to operating, maintenance and other employees whose work assignments are in the process and who could be affected by the recommendations or actions:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.10

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.119(e)(6): The employer did not ensure after the initial process hazard analysis, that the process hazard analysis was updated and revalidated at least every five (5) years by a team meeting the requirements of 29 CFR 1910.119 (e)(4):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 2 2 29 CFR 1910.119(e)(6): The employer did not ensure that the process hazard analysis was consistent with the current process:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(e)(7): The employer did not retain process hazards analyses, updates, or revalidations for each covered process, as well as the documented resolution of recommendations described in 29 CFR 1910.119(e)(5) for the life of the process:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(f)(1): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and which addressed the elements listed in 29 CFR 1910(f)(1)(i) through (f)(1)(iv):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.11

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(f)(1)(i)(A): The employer's written operating procedures covering the steps for each operating phase did not address initial startup:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

Note: This SAVE may be grouped with those of 29 CFR 1910.119(d) as appropriate, about missing process safety information related to operating procedures, such as, safe upper and lower limits for the process flow, temperature, or safety systems for detection, suppression systems, hazards of the chemicals in the process, and/or others.

2 29 CFR 1910.119(f)(1)(i)(B): The employer's written operating procedures covering the steps for each operating phase did not address normal operations:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(f)(1)(i)(C): The employer's written operating procedures covering the steps for each operating phase did not address temporary operations:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(f)(1)(i)(D): The employer's written operating procedures covering the steps for each operating phase did not address emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown executed in a safe and timely manner:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.12

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(f)(1)(i)(E): The employer's written operating procedures covering the steps for each operating phase did not address emergency operations:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

2 29 CFR 1910.119(f)(1)(i)(F): The employer's written operating procedures covering the steps for each operating phase did not address normal shutdown:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(f)(1)(i)(G): The employer's written operating procedures covering the steps for each operating phase did not address startup following a turnaround, or after an emergency shutdown:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with those of 29 CFR 1910.119(i) as appropriate.

4 29 CFR 1910.119(f)(1)(ii): The employer's written operating procedures did not address the requirements for the operating limits listed in 29 CFR 1910.119(f)(1)(ii)(A) and (B):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

5 29 CFR 1910.119(f)(1)(ii)(A): The employer's written operating procedures covering the operating limits did not address the consequences of deviation beyond such operating limits:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.13

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(f)(1)(ii)(B): The employer's written operating procedures covering the operating limits did not address the steps required to correct or avoid deviation beyond such operating limits:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

2 29 CFR 1910.119(f)(1)(iii): The employer's written operating procedures did not address the requirements for the safety and health considerations listed in 29 CFR 1910.119(f)(1)(iii)(A) through (f)(1)(iii)(E):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(f)(1)(iii)(A): The employer's written operating procedures covering safety and health considerations did not address the properties of, and hazards presented by the chemicals used in the process:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(f)(1)(iii)(B): The employer's written operating procedures covering safety and health considerations did not address the precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.14

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(f)(1)(iii)(C): The employer's written operating procedures covering safety and health considerations did not address the control measures to be taken if physical contact or airborne exposure occurs:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

2 29 CFR 1910.119(f)(1)(iii)(D): The employer's written operating procedures covering safety and health considerations did not address the quality control for raw materials and control of hazardous chemical inventory levels:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(f)(1)(iii)(E): The employer's written operating procedures covering safety and health considerations did not address special or unique hazards of the process when they exist:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)(IDENTIFY SPECIAL OR UNIQUE HAZARDS)

4 29 CFR 1910.119(f)(1)(iv): The employer's written operating procedures did not address the requirements for the safety systems and their functions:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

5 29 CFR 1910.119(f)(2): Operating procedures were not readily accessible to employees who work in or maintain the process:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.15

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.119(f)(3): The operating procedures were not 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, or changes to facilities:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119(l) about not properly following the management of change procedures where such changes affected the operating procedures as appropriate.

OPTION 2 2 29 CFR 1910.119(f)(3): The employer did not certify annually that the operating procedures are current and accurate:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(f)(4): The employer did not develop and implement safe work practices for employees and contractor employees 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:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with the lockout/tagout SAVEs 29 CFR 1910.147 as appropriate. This SAVE may be also grouped with 29 CFR 1910.119(j)(3) when maintenance personnel are involved or contractors doing maintenance work as appropriate.

145.16

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.119(g)(1)(i): The employer did not initially train each employee, presently involved in operating a process, in an overview of the process and in the operating procedures as specified in 29 CFR 1910.119(f):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 2 2 29 CFR 1910.119(g)(1)(i): The employer did not train each employee, before being involved in operating a newly assigned process, in an overview of the process and in the operating procedures as specified in 29 CFR 1910.119(f):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 3 3 29 CFR 1910.119(g)(1)(i): The initial training program for employees involved in operating a process did not include emphasis on the specific safety and health hazards of the process, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(g)(1)(ii): In lieu of initial training for those employees already involved in operating a process on May 26, 1992, the employer did not certify in writing that the employee had the required knowledge, skills, and ability to safely carry out the duties and responsibilities as specified in the operating procedures:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.17

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.119(g)(2): The employer did not provide refresher training at least every three years to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 2 2 29 CFR 1910.119(g)(2): The employer did not consult with employees in determining the appropriate frequency interval for refresher training:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 1 3 29 CFR 1910.119(g)(3): The employer did not prepare a record which contained the identity of the employee and the date that training was completed:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS)

OPTION 2 4 29 CFR 1910.119(g)(3): The employer did not prepare a means of verifying that the employee had received and understood the training required by 29 CFR 1910.119(g):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

5 29 CFR 1910.119(h)(2)(i): The employer, when selecting a contractor, did not obtain and evaluate information regarding the contract employer's safety performance and programs:

(a) (LOCATION)(IDENTIFY SPECIFIC SITE OPERATIONS AND/OR CONDITIONS)

145.18

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(h)(2)(ii): The employer did not inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

2 29 CFR 1910.119(h)(2)(iii): The employer did not explain to contract employers the applicable provisions of the emergency action plan required by 29 CFR 1910.119(n):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(h)(2)(iv): The employer did not develop and implement safe work practices consistent with 29 CFR 1910.119(f)(4), to control the entrance, presence and exit of contract employers and contract employees in covered process areas:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119(f)(4) as appropriate.

4 29 CFR 1910.119(h)(2)(v): The employer did not periodically evaluate the performance of contract employers in fulfilling their obligations as specified in 29 CFR 1910.119(h)(3):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119(h)(3) as appropriate.

145.19

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(h)(2)(vi): The employer did not maintain a contract employee injury and illness log related to contractor's work in process areas:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

2 29 CFR 1910.119(h)(3)(i): The contract employer did not assure that each contract employee was trained in the work practices necessary to safely perform his/her job:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(h)(3)(ii): The contract employer did not assure that each contract employee was instructed in the known potential fire, explosion or toxic release hazards related to his/her job and the process, and the applicable provisions of the emergency action plan:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119(h)(2)(ii) and (h)(2)(iii) as appropriate.

OPTION 1 4 29 CFR 1910.119(h)(3)(iii): The contract employer did not document that each contract employee had received and understood the training required by 29 CFR 1910.119(h)(3):

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS)

145.20

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.119(h)(3)(iii): The contract employer did not prepare a record which contained the identity of the contract employee, the date of the training, and the means used to verify that the employee understood the training required by 29 CFR 1910.119(h)(3):

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS)

2 29 CFR 1910.119(h)(3)(iv): The contract employer did not assure that each contract employee follows the safety rules of the facility including the safe work practices required by 29 CFR 1910.119(f)(4):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119(f)(4) as appropriate.

3 29 CFR 1910.119(h)(3)(v): The contract employer did not advise the employer of any unique hazards presented by the contract employer's work, or of any hazards found by the contract employer's work:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 1 4 29 CFR 1910.119(i)(1): The employer did not perform a pre-startup safety review for new facilities:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119(d) as appropriate.

145.21

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.119(i)(1): The employer did not perform a pre-startup safety review for modified facilities when the modification was significant enough to require a change in the process safety information:

(a) (LOCATION)(IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119(d) as appropriate.

2 29 CFR 1910.119(i)(2)(i): The pre-startup safety review did not confirm that prior to the introduction of highly hazardous chemicals to the process, that construction and equipment were in accordance with design specifications:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119(d) as appropriate.

3 29 CFR 1910.119(i)(2)(ii): The pre-startup safety review did not confirm that prior to the introduction of highly hazardous chemicals to the process, the safety, operating, maintenance, and emergency procedures were in place and were adequate:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119(d) as appropriate.

145.22

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.119(i)(2)(iii): The pre-startup safety review for new facilities did not confirm that prior to the introduction of highly hazardous chemicals to the process, a process hazard analysis had been performed and recommendations had been resolved or implemented before startup:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119(d) as appropriate.

OPTION 2 2 29 CFR 1910.119(i)(2)(iii): The pre-startup safety review for modified facilities did not confirm that prior to the introduction of highly hazardous chemicals to the process, the modified facility met the requirements contained in management of change, 29 CFR 1910.119(l):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119(d) and 29 CFR 1910.119(l) as appropriate.

3 29 CFR 1910.119(i)(2)(iv): The pre-startup safety review did not confirm that prior to the introduction of highly hazardous chemicals to the process, the training of each employee involved in operating a process had been completed:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.23

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going mechanical integrity of process equipment:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119(f)(4) as appropriate.

2 29 CFR 1910.119(j)(3): The employer did not train each employee involved in maintaining the on-going mechanical integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119(d) and 29 CFR 1910.119(f)(4) as appropriate.

3 29 CFR 1910.119(j)(4)(i): Inspections and tests were not performed on process equipment to maintain its mechanical integrity:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.24

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(j)(4)(ii): Inspections and testing procedures performed on process equipment to maintain its mechanical integrity, did not follow recognized and generally accepted good engineering practices:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: The process equipment included in this standard are pressure vessels and storage tanks, piping systems (including piping components such as valves), relief and vent systems and devices, emergency shutdown systems, controls (including monitoring devices and sensors, alarms, and interlocks), and pumps. (See 29 CFR 1910.119(j)(1)). This SAVE may by grouped with 29 CFR 1910.119(d)(3)(ii) as appropriate.

OPTION 1 2 29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment to maintain its mechanical integrity, was not consistent with applicable manufacturers' recommendations and good engineering practices, or more frequently determined to be necessary by prior operating experience:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: The process equipment included in this standard are pressure vessels and storage tanks, piping systems (including piping components such as valves, relief and vent systems and devices, emergency shutdown systems, controls (including monitoring devices and sensors, alarms, and interlocks), and pumps. (See 29 CFR 1910.119(j)(1)). This SAVE may by grouped with 29 CFR 1910.119(d)(3)(ii) as appropriate.

145.25

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.119(j)(4)(iii): Inspections and tests of process equipment were not included with the frequency determined to be necessary by prior operating experience:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 1 2 29 CFR 1910.119(j)(4)(iv): The employer did not document each inspection and test that had been performed on process equipment to maintain its mechanical integrity:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: The process equipment included in this standard are pressure vessels and storage tanks, piping systems (including piping components such as valves, relief and vent systems and devices, emergency shutdown systems, controls (including monitoring devices and sensors, alarms, and interlocks), and pumps. (See 29 CFR 1910.119(j)(1)).

145.26

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.119(j)(4)(iv): The documentation of the inspection or test that been performed on process equipment to maintain its mechanical integrity did not 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, and the results of the inspection or test:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: The process equipment included in this standard are pressure vessels and storage tanks, piping systems (including piping components such as valves, relief and vent systems and devices, emergency shutdown systems, controls (including monitoring devices and sensors, alarms, and interlocks), and pumps. (See 29 CFR 1910.119(j)(1))

2 29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (as defined by process information in 29 CFR 1910.119(d)) before further use or in a safe and timely manner:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: The process equipment included in this standard are pressure vessels and storage tanks, piping systems (including piping components such as valves, relief and vent systems and devices, emergency shutdown systems, controls (including monitoring devices and sensors, alarms, and interlocks), and pumps. (See 29 CFR 1910.119(j)(1)).

145.27

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(j)(6)(i): In the construction of new plants and equipment, the employer did not assure that equipment as fabricated was suitable for the process application for which it was used:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: The process equipment included in this standard are pressure vessels and storage tanks, piping systems (including piping components such as valves, relief and vent systems and devices, emergency shutdown systems, controls (including monitoring devices and sensors, alarms, and interlocks), and pumps. (See 29 CFR 1910.119(j)(1)). This SAVE may be grouped with 29 CFR 1910.119(d)(3)(ii) as appropriate.

2 29 CFR 1910.119(j)(6)(ii): Appropriate checks and inspections were not performed to assure that equipment was installed properly and consistent with design specifications and the manufacturer's instructions:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: The process equipment included in this standard are pressure vessels and storage tanks, piping systems (including piping components such as valves, relief and vent systems and devices, emergency shutdown systems, controls (including monitoring devices and sensors, alarms, and interlocks), and pumps. (See 29 CFR 1910.119(j)(1)). This SAVE may be grouped with 29 CFR 1910.119(d)(3)(ii) as appropriate.

145.28

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(j)(6)(iii): The employer did not assure that maintenance materials, spare parts and equipment were suitable for the process application for which they were used:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: The process equipment included in this standard are pressure vessels and storage tanks, piping systems (including piping components such as valves, relief and vent systems and devices, emergency shutdown systems, controls (including monitoring devices and sensors, alarms, and interlocks), and pumps. (See 29 CFR 1910.119(j)(1)). This SAVE may be grouped with 29 CFR 1910.119(d)(3)(ii) as appropriate.

2 29 CFR 1910.119(k)(1): The employer did not issue a hot work permit for work operations conducted on or near a covered process:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 1 3 29 CFR 1910.119(k)(2): The hot work permit did not document that the fire prevention and protection requirements in 29 CFR 1910.252(a) had been implemented prior to beginning the hot work operations:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.252(a) as appropriate.

145.29

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.119(k)(2): Hot work permits did not indicate the date(s) authorized for hot work and identify the object on which hot work was to be performed:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 3 2 29 CFR 1910.119(k)(2): Hot work permits were not kept on file until completion of the hot work operations:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(l)(1): The employer did not establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This standard does not cover "replacements in kind". This SAVE may be grouped with 29 CFR 119(d) and 29 CFR 1910.119(f)(1) as appropriate.

4 29 CFR 1910.119(l)(2)(i): The written procedures to manage changes did not assure that the technical basis for the proposed change was addressed prior to any change:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

5 29 CFR 1910.119(l)(2)(ii): The written procedures to manage changes did not assure that the impact of the change on safety and health was addressed prior to any change:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.30

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(l)(2)(iii): The written procedures to manage changes did not assure that the modifications to operating procedures were addressed prior to any change:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119(f)(3) as appropriate.

2 29 CFR 1910.119(l)(2)(iv): The written procedures to manage changes did not assure that the necessary time period for the change was addressed prior to any change:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(l)(2)(v): The written procedures to manage changes did not assure that the authorization requirements for the proposed change were addressed prior to any change:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(l)(3): Employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process were not informed of, and trained in, the change prior to start-up of the process or affected part of the process:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119 (g)(1), 29 CFR 1910.119(h)(3), or 29 CFR 1910.119(j)(3) as appropriate.

145.31

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(l)(4): A change covered by 29 CFR 1910.119 (l) resulted in a change in the process safety information required by 29 CFR 1910.119(d) and the process safety information was not updated:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119(d) and 29 CFR 1910.119(f)(1) as appropriate.

2 29 CFR 1910.119(l)(5): A change covered by 29 CFR 1910.119 (l) resulted in a change in the operating procedures or practices required by 29 CFR 1910.119(f), and such procedures or practices were not updated:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.119 (f)(1), 29 CFR 1910.119(h)(3) and 29 CFR 1910.119(l)(3) as appropriate.

3 29 CFR 1910.119(m)(1): The employer did not investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of a highly hazardous chemical in the workplace:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(m)(2): The investigation of an incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace, was not initiated promptly or within 48 hours following the incident:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.32

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.119(m)(3): The employer did not establish an incident investigation team to investigate an incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 2 2 29 CFR 1910.110(m)(3): The incident investigation team did not consist of at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(m)(4): A report was not prepared at the conclusion of the investigation of an incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(m)(4)(i): The report prepared at the conclusion of the investigation of an incident which resulted in, or-could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace, did not include the date of the incident:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.33

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(m)(4)(ii): The report prepared at the conclusion of the investigation of an incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace, did not include the date the investigation began:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

2 29 CFR 1910.119(m)(4)(iii): The report prepared at the conclusion of the investigation of an incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace, did not include a description of the incident:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(m)(4)(iv): The report prepared at the conclusion of the investigation of an incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace, did not include the factors that contributed to the incident:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(m)(4)(v): The report prepared at the conclusion of the investigation of an incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace, did not include any recommendations resulting from the investigation team:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.34

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.119(m)(5): The employer did not establish a system to promptly address and resolve the incident investigation report findings and recommendations:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 2 2 29 CFR 1910.119(m)(5): Corrective action and resolutions of the incident investigation report findings were not documented:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(m)(6): The incident investigation report was not reviewed with all affected personnel, including contract employees whose job tasks are relevant to the incident findings:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(m)(7): Incident investigation reports were not retained for at least five years:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

OPTION 1 5 29 CFR 1910.119(n): The employer did not establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38(a):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.38(a) as appropriate.

145.35

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.119(n): The employer's emergency action plan did not include procedures for handling small releases:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120(a), (p), and (q). This SAVE may be grouped with 29 CFR 1910.1200(h)(2) as appropriate.

2 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 are being followed:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(o)(2): The compliance audit required by 29 CFR 1910.119(o)(1) was not conducted by at least one person knowledgeable in the process:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

4 29 CFR 1910.119(o)(3): A report was not developed of the findings of the compliance audit required by 29 CFR 1910.119(o)(1):

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

145.36

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(o)(4): The employer did not determine and document an appropriate response to each of the findings of the compliance audit required by 29 CFR 1910.119(o)(1), and document that the deficiencies had been corrected:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

2 29 CFR 1910.119(o)(5): The employer did not retain the two (2) most recent compliance audit reports:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

3 29 CFR 1910.119(p)(1): The employer did not make all information necessary to comply with the section available to those persons responsible for compiling the process safety information required by 29 CFR 1910.119(d), those assisting in the development of the process hazard analysis required by 29 CFR 1910.119(e), those responsible for developing the operating procedures required by 29 CFR 1910.119(f), and those involved in incident investigations required by 29 CFR 1910.119(m), emergency planning and response 29 CFR 1910.119(n), and compliance audits 29 CFR 1910.119(o) without regard to possible trade secret status of such information:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)(SPECIFY WHAT-SECTION (S) OF THE STANDARD THAT WAS IN NONCOMPLIANCE)

NOTE: Nothing in this paragraph shall preclude the employer from requiring the persons to whom the information is made available under 29 CFR 1910.119(p)(1) to enter into a confidentiality agreements as set forth in 29 CFR 1910.1200.

145.37

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.119(p)(3): Employees and their designated representatives were not provided access to trade secret information contained within the process hazard analysis and other documents required to be developed by this standard:

(a) (LOCATION)(IDENTIFY SPECIFIC PROCESS OPERATIONS AND/OR CONDITIONS)

NOTE: This requirement is subject to the rules and procedures set forth in 29 CFR 1910.1200 (i)(1) through (i)(12).

145.38

OSHA Instruction CPL 2.35 CH-22 December 14, 1992 Office of General Industry Compliance Assistance

RESERVED FOR FUTURE USE

146

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