Recent Recommendation Status Updates

Open: 100% | Closed: 0%

Final Report Released On: June 03, 2025

2024-01-I-TN-4

Include physical, protective barriers as part of the standard design for liquid nitriding processes. These protective barriers shall be intended to isolate employees from molten salt releases.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

2024-01-I-TN-5

Develop a safety management system that incorporates industry guidance and includes, but is not limited to:

a. A hazard analysis program for assessing the nitriding process. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety, the National Fire Protection Association’s (NFPA) Standard for Ovens and Furnaces, and ASM International’s Handbook. The program shall apply to new and existing parts, assess parts for accumulation hazards and sealed cavities, and include non-routine tasks such as reprocessing unsatisfactory parts.

b. Written operating procedures for the nitriding process. The procedures shall be based on the information gathered from the hazard analysis program. The procedures shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety and the CCPS’s Guidelines for Writing Effective Operating and Maintenance Procedures.

c. A training program, including written materials, for the employees involved in the nitriding process. This program shall be based on the nitriding facility’s operating procedures and other relevant information from the hazard analysis program. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety.

d. An incident investigation program. This program shall include requirements for performing causal analysis, producing written reports, and communicating findings and corrective actions throughout the entire HEF Groupe organization. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety and the CCPS’s Guidelines for Investigating Process Safety Incidents.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

2024-01-I-TN-6

Develop and implement an effective and comprehensive Knowledge Management program for sharing knowledge throughout the HEF Groupe organization. Knowledge shall include all information from audits, hazard analyses, and incident investigations, including causal analyses and corrective actions recommended and taken. This program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Process Safety Knowledge Management.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

2024-01-I-TN-7

Develop and implement a comprehensive and effective Corporate Governance program. This program shall include regular audits of subordinate facilities throughout the organization, with tracking and accountability for implementation of all recommendations and corrective actions identified in the audits. Facility adherence to the safety management system recommended above shall be evaluated during the audits. The program shall require documentation of audit findings, prompt responses to deficiencies, development of corrective actions, and implementation of the corrective actions throughout the organization. This program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Implementing Process Safety Management.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

Open: 100% | Closed: 0%

Final Report Released On: June 03, 2025

2024-01-I-TN-1

Implement physical, protective barriers around the molten salt baths that isolate employees from hazardous releases at all locations that perform liquid nitriding.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

2024-01-I-TN-2

Develop a safety management system that incorporates industry guidance and includes, but is not limited to:

a. A hazard analysis program for assessing the nitriding process. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety, the National Fire Protection Association’s (NFPA) Standard for Ovens and Furnaces, and ASM International’s Handbook. The program shall apply to new and existing parts, assess parts for accumulation hazards and sealed cavities, and include non-routine tasks such as reprocessing unsatisfactory parts.

b. Written operating procedures for the nitriding process. The procedures shall be based on the information gathered from the hazard analysis program. The procedures shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety and the CCPS’s Guidelines for Writing Effective Operating and Maintenance Procedures.

c. A training program, including written materials, for the employees involved in the nitriding process. This program shall be based on the nitriding facility’s operating procedures and other relevant information from the hazard analysis program. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety.

d. An incident investigation program. This program shall include requirements for performing causal analysis, producing written reports, and communicating findings and corrective actions throughout the entire TS USA organization. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety and the CCPS’s Guidelines for Investigating Process Safety Incidents.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

2024-01-I-TN-3

For each TS USA facility, establish a position with specific professional expertise and experience in safety management systems, such as risk-based process safety. This position shall be responsible for TS USA’s safety management system, ensuring that HEF Groupe’s safety information is incorporated at the site level, and implementing regulatory and industry safety guidance.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

Open: 0% | Closed: 100%

Final Report Released On: October 11, 2022

2019-04-I-PA-3

(Superseded by 2023-02-I-LA-R4 from the Honeywell Geismar report)

Per the requirements in EPA Rule Procedures for Prioritization of Chemicals for Risk Evaluation Under the Toxic Substances Control Act, initiate prioritization to evaluate whether hydrofluoric acid is a High-Priority Substance for risk evaluation. If it is determined to be a High-Priority Substance, conduct a risk evaluation of hydrofluoric acid to determine whether it presents an unreasonable risk of injury to health or the environment. If it is determined to present an unreasonable risk of injury to health or the environment, apply requirements to hydrofluoric acid to the extent necessary to eliminate or significantly mitigate the risk, for example by using a methodology such as the hierarchy of controls.

Status: Closed - Reconsidered/Superseded
Recommendation Status Change Summary

Open: 100% | Closed: 0%

Final Report Released On: May 27, 2025

2023-02-I-LA-4

Per the requirements in EPA Rule Procedures for Prioritization of Chemicals for Risk Evaluation Under the Toxic Substances Control Act, initiate prioritization to evaluate whether hydrogen fluoride, including its anhydrous and aqueous acid forms, is a High-Priority Substance for risk evaluation. If it is determined to be a High-Priority Substance, conduct a risk evaluation of hydrogen fluoride to determine whether it presents an unreasonable risk of injury to health or the environment. If it is determined to present an unreasonable risk of injury to health or the environment, apply requirements to hydrogen fluoride to the extent necessary to eliminate or significantly mitigate the risk, for example by using a methodology such as the hierarchy of controls.

(Supersedes 2019-04-I-PA-R3 from the Philadelphia Energy Solutions Report)

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

Open: 100% | Closed: 0%

Final Report Released On: May 27, 2025

2023-02-I-LA-1

Perform a comprehensive third-party audit of the Geismar facility’s process safety and allied management systems as soon as practicable. The audit shall:

A. Be performed or led by an individual, firm, or team meeting the requirements outlined in paragraphs (b), (c), and (d) of Appendix E of this report.

B. Evaluate compliance with applicable federal standards (40 C.F.R. § 68 and 29 C.F.R. § 1910.119). In particular, the audit shall include the required elements that contributed to these incidents, including but not limited to:

1. management of change;
2. mechanical integrity;
3. quality assurance;
4. pre-startup safety reviews;
5. operating procedures; and
6. contractor management.

C. Evaluate other internal management systems that contributed to these incidents. In particular, the audit shall include but not be limited to:

1. management of organizational and personnel change;
2. management of safety-related capital projects;
3. organizational resilience; and
4. safe work practices including, but not limited to:

a. work permitting;
b. preparation of equipment for maintenance;
c. control of hazardous energy;
d. line break safety; and
e. personal protective equipment.

D. Use the Center for Chemical Process Safety’s Guidelines for Auditing Process Safety Management Systems as guidance to verify both the suitability of these systems and their effective, consistent implementation and performance.

E. Result in the development of a comprehensive report meeting the requirements outlined in paragraphs (e) and (f) of Appendix E of this report. If any findings are rejected, the rationale for and documentation supporting the merit of the rejection shall be included. The report in its entirety shall be made available to the Honeywell workforce at the Geismar, Louisiana; Baton Rouge, Louisiana; and Metropolis, Illinois, sites.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

2023-02-I-LA-2

Require periodic reporting updates from the Geismar site regarding the closure of the audit findings. The periodic updates shall continue until all audit findings are fully closed.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

2023-02-I-LA-3

Perform a Safer Technologies and Alternatives Analysis (STAA) for the Honeywell Geismar HFC-245fa unit. The STAA shall meet the requirements outlined in paragraphs (a) and (b) of Appendix F of this report.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

Open: 100% | Closed: 0%

Final Report Released On: June 24, 2024

2022-01-I-OH-7

Revise American National Standard ANSI/ISA 18.2-2016, Management of Alarm Systems for the Process Industries, to include performance targets for short-term alarm flood analysis so that users can evaluate alarm flood performance for a single alarm flood event. The performance targets should include:

a) number of alarm floods,
b) duration of each flood,
c) alarm count in each flood, and
d) peak alarm rate for each flood.

At a minimum, a target peak alarm flood rate should be defined, such as in the guidance provided by the ASM Consortium or Engineering Equipment and Materials Users Association (EEMUA), to establish trigger points that require alarm performance improvement actions.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

Open: 0% | Closed: 100%

Final Report Released On: June 24, 2024

2022-01-I-OH-2

Revise the Abnormal Situation Management policy to incorporate guidance provided by the ASM Consortium and the Center for Chemical Process Safety (CCPS). The revised policy should include, at a minimum:

a) A broader definition of abnormal situations, such as that defined by the CCPS,

b) Additional predictable abnormal situations and their associated corrective procedures. At a minimum include the following abnormal situations:

1) unplanned crude slate changes,
2) continued operation of the Crude 1 unit with the naphtha hydrotreater unit shut down, and
3) an emergency pressure-relief valve opening.

c) Guidance to determine when an abnormal situation is becoming too difficult to manage and the appropriate actions to take, such as shutting down a process, putting it into a circulation mode, or implementing proper procedures for bringing it to a safe state.

Status: Closed - Acceptable Alternative Action
Recommendation Status Change Summary

2022-01-I-OH-3

Develop and implement a policy or revise existing policy that clearly provides employees with the authority to stop work that is perceived to be unsafe until the employer can resolve the matter. This should include detailed procedures and regular training on how employees would exercise their stop work authority. Emphasis should be placed on exercising this authority during abnormal situations, including alarm floods.

Status: Closed - Acceptable Action
Recommendation Status Change Summary

Open: 0% | Closed: 100%

Final Report Released On: June 12, 2019

2018-01-I-OK-4

 

The International Association of Drilling Contractors (IADC) implemented this recommendation instead of API.

 

Develop a recommended practice on alarm management specifically for the drilling industry based on guidance in ANSI/ISA 18.2 Management of Alarm Systems for the Process Industries. The recommended practice will address the unique dynamic environment of the drilling industry and provide guidance on implementing a state-based alarm system for different operating modes (e.g., drilling, circulating, tripping, etc.). Include International Association of Drilling Contractors (IADC) in the development of this recommended practice.

Status: Closed - Acceptable Alternative Action
Recommendation Status Change Summary

Open: 0% | Closed: 100%

Final Report Released On: June 12, 2019

2018-01-I-OK-14

Participate in development of the recommended practice describe in recommendation 2018-01-OK-R4 to [American Petroleum Institute] API.

Status: Closed - Exceeds Recommended Action
Recommendation Status Change Summary

Open: 0% | Closed: 100%

Final Report Released On: June 12, 2019

2018-01-I-OK-19

Establish and implement safety regulations requiring entities who design oil and gas well drilling plans for wells in Oklahoma (e.g., operators) and entities who perform the drilling operation (e.g., drilling contractors) to develop and implement the following prior to conducting drilling operations:

(a) Detailed written operating procedures with specified steps and equipment alignment for all operations;

(b) Written procedures for the management of changes (except replacements in kind) in procedures, the well plan, and equipment;

(c) A risk assessment of hazards associated with the drilling plan;

(d) A requirement to follow Recognized and Generally Accepted Good Engineering Practices (RAGAGEP);

(e) Development of a Well Construction Interface Document between the operator and the drilling contractor prior to the commencement of drilling activities which at a minimum includes a bridging document and well plan specifying barriers and how to manage them;

(f) The performance and documentation of flow checks using acceptable methods at defined points during the operation for a specified duration; and

(g) A requirement for employee participation, similar to the Employee Participation requirement in the OSHA PSM standard.

Status: Closed - Unacceptable Action/No Response Received
Recommendation Status Change Summary

Open: 0% | Closed: 100%

Final Report Released On: December 29, 2022

2018-02-I-WI-13

 

The American Fuel & Petrochemical Manufacturers (AFPM) implemented this recommendation instead of API.

 

Using API’s processes to determine the appropriate safety product, develop a publicly available technical publication for the safe operation of fluid catalytic cracking (FCC) units. The document should be applicable to both new and existing units. Include the following topics at a minimum:

a) Description of typical FCC unit hazards, including air leaks into hydrocarbon systems or hydrocarbon leaks into air systems that could form a flammable mixture during transient operation (startup, shutdown, standby, and the actions required to transition between these modes). If needed, include differences between possible reactor/regenerator configurations;

b) Recommended practices for safeguards to control FCC unit hazards;

c) Recommended monitoring for process safety during FCC unit transient operations;

d) Recommended emergency operating procedures for FCC-specific scenarios;

e) PHA guidance for key FCC-specific scenarios, including transient operation;

f) Recommended FCC-specific field and board operator process safety training topics and methods;

g) Guidelines for process safety assessments of FCC units; and

h) Incorporate lessons learned from this CSB investigation and the CSB’s ExxonMobil Torrance Refinery Electrostatic Precipitator Explosion investigation throughout the document and include references in the document’s bibliography.

Status: Closed - Acceptable Alternative Action
Recommendation Status Change Summary

Open: 100% | Closed: 0%

Final Report Released On: March 13, 2025

2024-01-I-CA-8

Revise API RP 556 Instrumentation, Control, and Protective Systems for Gas Fired Heaters, or successor API products, with the following:

1. Requirements for proper response to high tube metal temperatures, including guidance to alert operators when safe operating limits are exceeded and to specify predetermined response actions, such as shutting down the fired heater remotely. The predetermined response actions must include actions that specify when to stop troubleshooting and remove personnel from the vicinity of the fired heater;

2. Design requirements (“shall” rather than “should” language) for protecting fired heaters from low process flow where process piping diverges downstream of a flow meter. Requirements may include achieving proof of flow to the heater through valve position indicators and interlocks on branch 

3. Engineering safeguard requirements (“shall” rather than “should” language) to detect and prevent afterburning in fired heaters. These requirements may include the use of instrumentation such as combustibles measurements, flame detectors, and/or thermocouples that measure tube metal, flue gas, and process fluid temperatures. The requirements shall address monitoring capability from the control room.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary