Text For Citation: 01 Item/Group: 010 Hazard:

29 CFR 1910.119(e)(3): The process hazard analysis did not address: 29 CFR 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.); On or about and prior to April 8, 2021, for the PHA Revalidation, High Temp Review; the process hazard revalidation failed to address engineering and administrative controls applicable to the hazards and their interrelationships: in that; a. For the Esterification node, the employer inaccurately claimed the engineering control "rupture disk" (Line 18) when "potential to blow rupture disk" (Line 14) was listed as a potential catastrophic event to be prevented for the listed hazard/consequence "build pressure in the kettle" and "potential to blow rupture disk." When "potential to blow rupture disc" was listed as a potential catastrophic event to be prevented from occurring, the employer claimed the rupture disc as an engineering control/safeguard against itself. b. For the Esterification node, the employer failed to address administrative controls interrelated to the hazards, such as but not limited to a design specification for gaskets and gasket materials, a quality assurance plan for process vessels and a mechanical integrity procedure for gasket repair and replacement; when the employer listed the hazard of "vapor/liquid release" (Line 43) with consequences of "employee exposure, environmental release, fire and explosion" (Lines 43-45) related to a failed gasket. Additionally the employer inaccurately claimed the listed "Spill response and equipment," "Ventilation," Fire suppression system," "Containment," "All Condensers in electrically classified areas" and "PPE" as safeguards (Lines 43-49) to prevent or detect a vapor/liquid release from a failed gasket. c. For the Esterification node, the employer inaccurately claimed the engineering control "rupture disk" (Line 29) when "potential to blow rupture disk" (Line 25) was listed as a potential catastrophic event to be prevented for the listed hazard/consequence "build pressure in the kettle" and "potential to blow rupture disk." When "potential to blow rupture disc" was listed as a potential catastrophic event to be prevented from occurring, the employer claimed the rupture disc as an engineering control/safeguard against itself. Additionally the employer inaccurately claimed the listed "Spill response and equipment," "Containment," and "PPE" as safeguards (Lines 27-28 and 30) to prevent, detect, or otherwise effect the pressure increase to, or overpressure of a reactor vessel from condenser vent line blockage. d. For the Esterification node, the employer inaccurately claimed the engineering control "rupture disk" (Line 36) when "potential to blow rupture disk" (Line 32) was listed as a potential catastrophic event to be prevented for the listed hazard/consequence "build pressure in the kettle" and "potential to blow rupture disk." When "potential to blow rupture disc" was listed as a potential catastrophic event to be prevented from occurring, the employer claimed the rupture disc as an engineering control/safeguard against itself. Additionally the employer inaccurately claimed the listed "Spill response and equipment," "Containment," and "PPE" as safeguards (Lines 34-35 and 37) to prevent, detect, or otherwise effect the pressure increase to, or overpressure of a reactor vessel from condenser vent line blockage. e. For the Esterification node, the employer inaccurately claimed the engineering control "Kettle temperature controller (redundant system)" (Line 97) for the listed hazards "No display" and "Temperature display below actual temperature" and listed consequences "Potential to overheat kettle, possible pressure," "potential to blow rupture disk," "possible environmental release," "Potential employee exposure" and "Possible fire" (Lines 99-103) for preventing reactor vessel temperature controller failure. When the employer's PHA WHAT-IF question listed the failed high temperature controller as causing an overpressurization hazard, the employer claimed the failed controller as an engineering control/safeguard against itself. f. For the Esterification node, the employer inaccurately claimed the engineering control "rupture disk" (Line 181) when "potential to blow rupture disk" (Line 177) was listed as a potential catastrophic event to be prevented for the listed hazard/consequence "build pressure in the kettle" and "potential to blow rupture disk." When "potential to blow rupture disk" was listed as a potential catastrophic event to be prevented from occurring, the employer claimed the rupture disk as an engineering control/safeguard against itself. g. For the Esterification node, the employer failed to address administrative controls interrelated to the hazards, such as but not limited to a design specification for gaskets and gasket materials, a quality assurance plan for process vessels and a mechanical integrity procedure for gasket repair and replacement; when the employer listed the hazard/consequences (Lines 194-197) of "Possible explosion/fire," Potential employee exposure," "Potential employee injury" and "Possible environmental release" related to in process reactor vessel manway use. h. For the Esterification node, the employer inaccurately claimed the engineering control "rupture disk" (Line 208) when "potential to blow rupture disk" (Line 207) was listed as a potential catastrophic event to be prevented for the listed hazard/consequence "build pressure in the kettle" and "potential to blow rupture disk." When "potential to blow rupture disc" was listed as a potential catastrophic event to be prevented from occurring, the employer claimed the rupture disc as an engineering control/safeguard against itself.