OSHA initiated an inspection on Aug. 4, 2015, under its national emphasis program focused on chemical manufacturers. Inspectors found deficiencies in the employer’s equipment process safety information, process hazard analysis, written operating procedures, contractor safety, equipment inspection and testing along with management of process changes, resulting in the citations.
PLEASE NOTE: this OSHA inspection cited many items that are NOT often seen in OSHA citations. It is a MUST see for any process safety professional. OSHA also offers “abatement suggestions” to some of their PSM citations. This inspection involved the following key areas:
- not securing intervening valves before/after RVs in the OPEN position (ASME Section VIII, UG-125, Appendix M)
- hiring a contractor to work on the Nitrogen system, which is used in blanketing vessels in the process and hiring a sprinkler contractor to work on the storage tank deluge system and not treating the contractors as a PSM contractors
- P&IDs not up-to-date
- Vessels lacking performance data (i.e. MAWP) had not been determined they were “fit for service”
- Facility had done a blast radius study, but had not considered the consequences in their PHA Facility Siting Analysis
- GREAT CATCH on Start-Up after ESD procedure assumes the process equipment is empty
- Flame arrestors and bonding/grounding stations not part of the MI inspection/testing program
- Did not bench test all RVs to establish a change out schedule and those they did bench test showed a change out schedule of 2 years and the schedule was not being followed
- NDT/NDE done by unqualified personnel without supervision of certified personnel
- No MOCs done on closure of PHA/Audit items
- Written HAZCOM program did not include how bulk tanks would be labeled and the ethyl chloride tank was not labeled
Here is the breakdown of the citations: