The OSHA offices in NY state have been very busy this year! This is about the fifth or sixth significant PSM case from that state in 2012. The others were Ammonia refrigeration; this one involved flammable liquids and gases. Items that OSHA took issue with include:
- PSI Issues
- no block flow for process
- P&ID not accurate:
- missing instrumentation, valving, vents, PSV
- tanks removed from process but still on P&ID
- vents with plugs not shown on P&ID
- No relief system design basis
- RAGAGEP Issues
- piping on vent stack after flame arrester was PVC and showed signs of damage (referenced NFPA 30 27.4.4.1)
- ethanol emergency vent was below the roof line (referenced NFPA 90 and 69)
- emergency vents on flammable tanks were in line with building intakes (referenced NFPA 90 and 69)
- spill containment for flammable tanks had an unsecured/open valve to a WWTP (referenced NFPA 30 5.4)
- PHA Issues
- did not consider the consequences of failures of engineering and administrative controls, such as interlocks on doors to gas houses
- no written schedule to address PHA done in August 2011 (NOTE: the inspection began on 2/13/12, within 6 months of the completion of the PHA)
- employees not involved in the PHA
- Operating Procedures Issues
- no start-up, shutdown and emergency shutdown of the ethanol unit
- MI Issues
- did not correct deficiencies outside acceptable limits
- valve control arm being held closed with rubber band
- thermocouple and conduit not supported
- pump control panel pulled from wall and supported by conduit
- LEL meter(s) bracket broken and meter held by conduit
- Valving (shutoff, emergency or bypass) not labeled or identified
- E-stop button outside process room for ethanol pump was missing the entire mushroom button
- Grounding strap to a propellant truck was not attached to metal on the truck
- Product inlet valve to a tank had the manufacturers flow direction opposite of what direction the product was flowing
- 3-year Audit Issues
- no compliance audits performed for the alcohol unit
Click Here to download the Official OSHA PSM Citations (pdf)
Some other issues that found that are not that common and deserve to be called out:
- wood pallets were stored under a propane tank
- wet floors and resin pellets on floor creating slip hazards
- a whole list of uncovered floor drains and openings in flooring
- aisles/passageways blocked with storage
- water hose on entire length of catwalk
- ladderway and platform guarding
- fixed stairs not provided where travel was daily/shift (workers using a fixed ladder to access top of machine to clear jams and a 12′ step ladder leaning against a tank to access top of tank)
- overhead door was being used as an exit
- exit doors blocked by pallets of material
- emergency lights not working
- nine locations of either no posted exit or no directional exit signs
- using MEK on a workbench where a four way receptacle was located
- paint booth floor was lined with cardboard
- electrical wiring within 20′ of paint booth was not Class I Div 2
- light attached to front edge of paint booth not rated for HAZLOC
- no fall protection for when employees climbed the palletizer and conveyor (11′) to clear jams
- employees observed doing servicing and maintenance without LOTO
- no machine specific LOTO procedures for a whole host of machines (fillers, cappers, bottle feeders, robots, blow mold machines, etc.)
- blocked fire extinguishers
- no fire extinguisher training
- damaged storage racks were not secure due to damaged support structures
- 48 guarding issues noted involving ingoing nip points, robot arms, drill press chuck, agitator arms
- guarding creating a hazard
- woodworking machines in maintenance dept not guarded
- shafting and shaft ends with set screws not guarded
- pulleys and horizontal belts not guarded
- chains and sprockets not guarded
- compressed air for cleaning was not reduced down to 30 psi
- damaged extension cords
- pallet jack blocked breaker panel
- cords and conduits pulled from fittings
- no strain relief on cords
- overhead cranes had broken e-stop buttons
- open 480 volt cabinet
- missing blanks in breaker panel
- outlet covers missing
- fan plugs missing ground pin
- using relocatable power taps and extension cords in place of permanent wiring
- unqualified employees doing electrical work not trained in electrical safety related work practices or PPE
- no electrical safety related work practices
Click Here to download the official OSHA Citations for those listed above (pdf)