OSHA has cited the company with three repeat and four serious violations following a June inspection as part of the agency’s Process Safety Management Covered Chemical Facilities national emphasis program (NEP). Proposed penalties total $99,000. The repeat citations issued for the process safety management standard violations include failing to inspect and test process equipment consistent with applicable manufacturers’ recommendations and good engineering practices, ensure that process equipment complies with recognized and generally accepted good engineering practices, and properly label containers holding hazard chemicals. Similar violations were cited at the company’s work site in Live Oak, Fla., in April 2008 and at the work site in Russellville, Ala., in September 2010. Serious violations include failing to correct deficiencies in process equipment, ensure that process safety information pertaining to equipment includes design codes and standards and establish and implement written procedures to manage changes of the process. Here is a breakdown of the citations…
Process Safety Information
- 1910.119(d)(3)(i)(F) – PSI did not contain any design codes or standards for interlocks and safety instrument controls (Serious; $7K)
- Five (5) specific safety systems called out: 1) hi and lo pressure cutouts on compressors, 2) Compressor Oil pressure differential cut out, 3) hi temp cut out, 4) E-Stop buttons, 5) Level controls
- 1910.119(d)(3)(ii) – emergency ventilation system did not comply with RAGAGEP ASHRAE 15 or IIAR-2 (REPEAT; $35,000)
- three machinery rooms did not meet the RAGAGEP for ventilation
Mechanical Integrity
- 1910.119(j)(5) – deficiencies in equipment outside acceptable limits were not corrected in a safe and timely manner (Serious; $7K)
- Three (3) instances in July 2012 where OSHA found issues:
- Machinery Room NORMAL ventilation fans not functioning properly
- Machinery Room EMERGENCY ventilation fans not functioning properly
- Detection and Alarm system not functioning
- Three (3) instances in July 2012 where OSHA found issues:
- 1910.119(j)(4)(iii) – frequency of inspections on process equipment was not consistent with RAGAGEP (REPEAT; $35,000)
- Five (5) pressure vessels were found to have not been inspected by an independent 3rd party consistent with the schedule in IIAR Bulletin 110
- Three (3) sets of pressure relief valves (PSV) were found to have not been inspected at a frequency consistent with the schedule in IIAR Bulletin 110
- Six (6) pumps and three (3) compressors were found to have not been inspected at a frequency consistent with the schedule in IIAR Bulletin 110 (NOTE: although Bulletin 110 is not specifically called out in this “instance” I am assuming OSHA meant to reference the same bulletin as in the other two (2) instances in this citation)
Management of Change
- 1910.119(l)(1) – did not implement MOC procedures for changes to machinery room ventilation systems (Serious; $7K)
Audits
- 1910.119(o)(4) – did not address two audit findings from the 2008 PSM audit (Serious; $7K)
- One audit finding that was not addressed was related toP&IDs to show instrumentation
- The other audit finding that was not addressed was related to not updating an annual inspection
HAZCOM
- 1910.1200(f)(5)(i) – a five gallon container of refrigeration oil was not marked to identify its contents (REPEAT; $1,000)
- 1910.1200(f)(5)(ii) – a five gallon container of refrigeration oil was not marked with appropriate hazard warnings (REPEAT; $0)
CLICK HERE for the PSM Citations
CLICK HERE for the HAZCOM Citations