OSHA has cited the chemical manufacturer with 12 serious violations at the chemical manufacturer’s Nitro facility after a July investigation initiated following the death of a worker performing sandblasting activities. During the sandblasting activities, the airline for a supplied air hood was hooked up to a nitrogen gas line and the worker became unconscious. The serious violations related to the fatality included failing to label nitrogen lines at connection points and not ensuring that breathing air couplings were incompatible with other gas systems. Other serious violations included failing to provide training on hazardous chemicals, ensure stairways wider than 44 inches have handrails on each side, provide process safety information and process hazard analysis, use approved electrical chain hosts, develop a mechanical integrity program, and document that equipment complied with recognized and generally accepted good engineering practices. Here is a breakdown of the citations…
Proposed penalties against the chemical manufacturer total $42,700.
- 5(a)(1) – Nitrogen pipeline located next to a supplied air pipeline was not properly labeled. The label was not close to, or adjacent to, the connection point resulting in an employee connecting to the nitrogen line instead of the supplied airline which caused an asphyxiation death during sandblasting operations. (Serious; $7K)
- OSHA is mandating the facility take the following abatement actions:
- Establish and implement a plant wide labeling program, including training, following guidelines established in ASME-ANSI A13.1-2007 Scheme for Identification of Piping Systems.
- Labeling shall be applied close to valves or flanges and adjacent to changes in direction, branches and where pipe pass through walls or floors; and at intervals on straight pipe runs sufficient for identification.
- Utilize the correct color scheme of white lettering on a safety blue background for air, and a user defined blue or purple or white or gray, or black background with white lettering (black lettering for a white background) for Nitrogen.
- For pipe that is 1.5″ in diameter, the labels are to be 8″ in length and the lettering is to be .75″.
- OSHA is mandating the facility take the following abatement actions:
- 1910.23(d)(1)(iv) – A stairway going between the first and second floor was measured at 54.5 inches wide and it only had one handrail that was located on the left side descending. (Serious; $2,100)
- 1910.119(d)(3)(i)(C) – Flammable process areas (2) did not have their electrical classification for hazardous locations established. (Serious; $3,500)
- 1910.307(c) – Electric chain hoist were used at the process reactors to lift containers of flammable liquids onto the work deck and they were not electrically approved for a Class I Div 2 area. (Serious; $0)
- 1910.119(d)(3)(ii) – Equipment handling flammable liquids did not have documentation that it met Recognized and Generally Accepted Good Engineering Practices (RAGAGEP). (Serious; $0)
- 1910.119(e)(3)(vii) – The PHA did not include a qualitative evaluation of the range of safety and health effects associated with the hazards identified in the PHA. (Serious; $3,500)
- 1910.119(e)(5) –
- An action item from the June 2011 PHA to verify that a nitrogen purge at four (4) cubic feet per minute would inert the reactor with an oxygen level of less than 6% to prevent a fire had not been completed at the time of the July 2012 inspection. (Serious; $4,900)
- An action item from the June 2011 PHA to verify that breaking vacuum on the reactor with a nitrogen purge at 4 cubic feet per minute would inert the reactor with an oxygen level of less than 6% to prevent a fire had not been completed at the time of the July 2012 inspection. (Serious; $0)
- 1910.119(f)(1)(i)(D) – Written operating procedures (batch sheets) for the processes containing greater than 10,000 pounds of flammable liquids did not contain an emergency shutdown procedure and the conditions that would require an emergency shutdown. (Serious; $4,900)
- 1910.119(f)(4) – Safe Work Practices were not developed for breaking into process lines that are used to transport flammable liquids from one vessel to another. (Serious; $0)
- 1910.119(j)(2) – No mechanical integrity program that included tests and inspections of pumps, piping, and gauges used in process areas that handle flammable liquids. (Serious; $4,900)
- 1910.134(i)(8) – Breathing air couplings were not incompatible with other gas systems to prevent inadvertent servicing of airline respirators with non-respirable gases or oxygen. (Serious; $7K)
- 1910.1200(h)(1) – Employees working in an area of the plant with an active nitrogen piping system were not provided with information and training on the hazards of nitrogen in their work area at the time of their initial assignment. (Serious; $4,900)
- 1910.22(d)(1) – employees using the roof of an office as s storage area with equipment, storage of parts and pallets, did not have the load rating marked. (Other-than-Serious; $0)
- 1910.95(d)(1) – Employer provides hearing protection and training but did not develop and implement a monitoring program. (Other-than-Serious; $0)
- 1910.119(c)(1) – no written employee participation program. (Other-than-Serious; $0)
- 1910.134(d)(1)(iii) – Employer did not identify and evaluate the respiratory hazards associated with sand blasting operations inside railcars which contain creosote and coal tar pitch. (Other-than-Serious; $0)
- 1910.212(a)(1) – employee’s hands are approximately 10″ from the rotating chuck and bit of a Clausing Drill Press, which was not equipped with a chuck guard when employees drilled holes in aluminum plates. (Other-than-Serious; $0)
- 1910.212(b) – The drill press was not anchored to prevent walking or moving. (Other-than-Serious; $0)
CLICK HERE (pdf) for the citations.