Text For Citation: 01 Item/Group: 002C Hazard:

29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not address human factors. (a) The 2011 process hazard analysis did not address human factors associated with steaming the dump line from Stage 1 Reactor R-109 to Outlet Reaction Buffer Drum Tank D-101, for clearing plugged lines with steam in that a human factor evaluation would have noted that the sight glass was located approximately three feet below the operator's eye level, or 33 inches above the catwalk floor, and therefore the position of the equipment impacted the ability to rapidly escape from a leak of hot process chemicals, such as phenol, BPA, acetone and hydrochloric acid. In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification. This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.