29 CFR 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.
A. The employer did not ensure that written operating procedures related to the facility’s car seal program were implemented.
This violation was identified during onsite inspections from November 2009 to March 2010. The employer developed a car seal program signed by plant management on June 8, 2004, yet requirements of this policy to car seal or lock open any intervening valve were not carried out. As part of the Owner-User Program, the facility was required to report to the Utah State Division of Boilers and Elevators they were complying with their internal car seal program. Although the program and policy had been developed, the employer did not follow the requirements of car sealing or locking open any intervening valve.
During field inspections, more than 50 intervening valves were noted NOT to be car-sealed or locked open.
Examples of such include, but not limited to, Valve PF 14192 protecting Vessel Serial #15195.
By not implementing and following the facility’s internal car seal program and procedure, valves could be inadvertently closed isolating relief valves. In the event of an equipment failure due to an intervening valve being closed, employees could be exposed to hazardous situations such as fires, explosions, and/or chemical releases which can result in serious injury or death. This may be a system-wide occurrence that requires evaluation of all intervening valves throughout the facility.