OSHA has cited an industrial gas manufacturer for 19 serious safety violations following an inspection at its repackaging facility. The inspection began in May under OSHA’s national emphasis program for process safety management for covered chemical facilities. Proposed fines total $49,200. Here is a breakdown of the actual citations:
Citation 1 Item 1
Type of Violation: Serious; $2,000
29 CPR 1910.106(b)(2)(vii)(c)(3): Walls of the diked area were not designed to be liquid tight.
The containment wall for the 3500 gallon atmospheric storage tank containing acetone, a Category 1 flammable liquid, had an open drain pipe designed into the dike.
Corrected During Inspection
Citation 1 Item 2
Type of Violation: Serious; $2,000
29 CFR 1910.106(e)(2)(iv)(d): Flammable liquids were not drawn from or transferred into vessels, containers, or portable tanks within a building only through a closed piping system, from safety cans, by means of a device drawing through the top, or from a container or portable tanks by gravity through an approved self-closing valve.
Employees dispensed acetone, a Category I flammable liquid, into compressed gas cylinders through in-plant piping with manually closing valves.
Citation 1 Item 3
Type of Violation: Serious; $2,000
29 CFR 1910.106(e)(9)(iii): Combustible waste material and residues in a building or unit operating area were not kept to a minimum, stored in covered metal receptacles and disposed of daily.
Paper towels with acetone were disposed in open plastic trash receptacles.
Citation 1 Item 4
Type of Violation: Serious; $2,800
29 CFR 1910.119(d): The employer did not complete a compilation of written process safety information pertaining to the equipment in the process, the technology of the process, and the equipment in the process before conducting the process hazard analysis.
The employer failed to compile PSI before conducting the PHA to include the required schedule for inspection, testing and servicing of equipment such as but not limited to the compressor oil, belts, and crankcase.
Citation 1 Item 5
Type of Violation: Serious; $2,800
29 CFR 1910.119(d)(3)(i)(B): Process safety information pertaining to the equipment in the process did not include the piping and instrument diagrams (P&ID’s).
a) The employer did not ensure that the written process safety information included all the necessary information pertaining to the equipment in the process when an existing shutoff valve between Compressors # 1, 2, 3 and 4 and the high pressure dryer was not represented on P&ID sheet # B09, B11, B13, & B15.
b) The employer did not ensure that written process safety information including all the necessary information pertaining to the equipment in the process in that the existing pressure gauge and valve at the bottom of the high pressure dryer system’s flash arrestor for systems #1, 2, 3, & 4 were not represented on P&ID sheet# B09, B11, B13 & B15.
c) The employer did not ensure that written process safety information accurately reflected existing equipment in the process in that valve #X168J in high pressure dryer system #1, valve #X181J in high pressure dryer system #2, valve #X194J in high pressure dryer system #3, however these valves do not exist in the plant process.
d) The employer did not ensure that the written process safety information included all the necessary information pertaining to the equipment in the process when an existing valve installed in Fill Rack #7 was not represented on P&ID sheet #B17.
e) The employer did not ensure that the written process safety information included all the necessary information pertaining to the equipment in the process when the fail safe position of the nitrogen emergency automatic valve was not identified on P&ID sheet# B02.
Citation I Item 6
Type of Violation: Serious; $2,800
29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting.
The 2007 and 2012 PHAs did not address potential acetylene vapor cloud explosion scenarios and the associated over pressure impact on an occupied wooded framed building located 25 feet from the compressor room and approximately 100 feet from acetylene trailers.
Citation 1 Item 7
Type of Violation: Serious; $2,800
29 CFR 1910.119(e)(5): The employer did not establish a system to assure that the recommendations were resolved in a timely manner and that the resolution was documented.
a) A 2007 PHA line 1.24 action item was to update P&IDs with piping specifications. The current P&IDs do not include piping specifications.
b) A 2007 PHA line 1.7 action item was to update P&ID sheet #B02 to reflect correctly PRV 113 pressure setting of 20 PSIG. The P&ID currently has PRV 113 labeled with a pressure setting of 15 PSIG.
Citation 1 Item 8
Type of Violation: Serious; $2,800
29 CFR 1910.119(f)(1): The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process.
The employer did not write operating procedure for starting up the Rexarc Generator after a prolonged shutdown or return to service.
Citation 1 Item 9
Type of Violation: Serious; $2,800
29 CFR 1910.119(f)(1)(iv): The employer’s written operating procedures did not address requirements for the safety systems and their functions.
a) The “Acetylene Operations Critical Operating Parameters” chart did not include the critical operating parameters and safety systems, including but not limited to PRVs and nitrogen emergency shutdown system, for the acetylene trailer operation.
b) The employer did not specify safety systems, including but not limited to PRVs and mercoid switches, and their function in operating procedures, including but not limited to
- “Acetylene Compressor Startup Procedure”
- “Rexarc High Pressure Dryer Operating Procedure”
- “Acetylene Compressor Shutdown Procedure”, and/or the
- “Acetylene Operations Critical Operating Parameters”
Citation 1 Item 10
Type of Violation: Serious; $2,800
29 CFR 1910.119(f)(4): The employer did not develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel.
The employer failed to implement an adequate safe work practice regarding control and accountability of outside contractors entering/ exiting the facility.
Citation 1 Item 11
Type of Violation: Serious; $2,800
29 CFR 1910.119(h)(2)(i): The employer, when selecting a contractor, did not obtain and evaluate information regarding the contract employer’s safety performance and program.
The employer did not evaluate the health and safety programs or the performance of contractors including, but not limited to electrical, fire suppression, and maintenance contractors that worked on the covered process.
Citation 1 Item 12
Type of Violation: Serious; $2,800
29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment.
a) The employer did not establish and implement written procedures for inspecting process piping containing acetylene gas at pressures of 5 to 400 PSI.
b) The employer did not establish and implement written procedures for inspecting, testing and changing out flash arrestors in the acetylene filling manifold.
Citation 1 Item 13
Type of Violation: Serious; $2,800
29 CFR 1910.119(j)(4)(ii): Inspections and testing procedures performed on process equipment to maintain its mechanical integrity did not follow recognized and generally accepted good engineering practices (RAGAGEP).
The employer did not follow RAGAGEP such as, but not limited to, NFPA 51A when they failed to conduct hydrostatic testing inspection as required on process piping containing acetylene at 5 to 400 PSI.
Citation 1 Item 14
Type of Violation: Serious; $2,800
29 CFR 1910.119(j)(4)(iv): The documentation of each inspection and test that was performed on the process did not identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.
The acetylene filling process has been active since 2002, the employer failed to maintain documentation of data for inspection and testing activities conducted prior to 2012.
Citation 1 Item 15
Type of Violation: Serious; $2,800
29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process .safety information on paragraph (d) of this section) before use.
a) Mercoid switches in panel were missing cover plates.
b) Pigtails for small cylinders (B & MC) were used to fill cylinders with acetylene gas while the reinforcement cover was pinched and frayed.
c) Employees charged compressed gas cylinders on line 2 while flash arrestor was labeled “bad”.
d) Compressor 4 was in use with a vibrating acetylene line due to motor belt deficiency.
Citation 1 Item 16
Type ofViolation: Serious; $2,800
29 CFR 1910.119(l)(1): The employer did not establish or implement written procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process.
A 1 inch flow restrictor was installed on the recompression manifold without a management of change review.
Citation 1 Item 17
Type of Violation: Serious; $2,800
29 CFR 1910.119(l)(5): When a change covered by this paragraph resulted in a change in the operating procedures or practices required by paragraph (f) of this section, such procedures or practices were not updated accordingly.
Operating procedures were not updated after a change to the high pressure dryer manifold affected a change to the dryer condensate draining process.
Corrected During Inspection
Citation 1 Item 18
Type of Violation: Serious; $2,000
29 CFR 1910.147(c)(4)(i): Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section.
Employees locked out equipment, including but not limited to compressors, to conduct service/repairs without equipment specific procedures.
Citation 1 Item 19
Type of Violation: Serious; $2,000
29 CFR 1910.178(l)(1)(i): The employer did not ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation specified in this paragraph(1).
Employees operated fork trucks without completing operator training. Fork trucks were used to move empty and full tanks of acetylene gas.
Corrected During Inspection
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