The owner or operator has not established a system to promptly address the Process Hazard Analysis (PHA) teamÂs findings and recommendations; assured that the recommendations are resolved in a timely manner and documented; documented what actions are to be taken; completed actions as soon as possible; developed a written schedule of when these actions are to be completed; and communicated the actions to operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations. [68.67(e)]The PHA has not been updated and revalidated by a team every five years after the completion of the initial PHA to assure that the PHA is consistent with the current process. [68.67(f)]. The operator has not followed recognized and generally accepted good engineering practices for inspections and testing procedures. [68.73(d)(2)]. The operator has not ensured that the frequency of inspections and tests of process equipment is consistent with applicable manufacturers recommendations, good engineering practices, and prior operating experience. [68.73(d)(3)]