Another OSHA PSM citation with some interesting citations. In this one, the company:
- was using Global FM Engineering Data Sheets as their RAGAGEP(s) for Rupture Disk sizing and Fire Protection, but failed to list these data sheets in their PSI as officially adopted RAGAGEPs.
- had multiple pieces of equipment on the system that were not tagged, marked or labeled with information to identify equipment on the system that was represented on the company’s P&IDs
- had approximately 10 instances occurred where equipment documented on the P&IDs were not installed on the PSM covered systems
- had approximately 3 instances occurred where equipment on the PSM covered systems were not drawn in the correct location on the P&IDs
- used a state code to design its secondary containment but was not listed as the design RAGAGEP in the PSI
OSHA cited the plastics resin manufacturer for one willful, five serious and one other-than-serious safety violation after it opened an investigation under the national emphasis program for process safety management. Here is a breakdown of the citations: