An OSHA PSM investigation at a nationwide chemical manufacturer and distributor produced 11 serious violations with penalties totaling $60,500. One of the hazards identified was formaldehyde, which is manufactured for use in various industrial applications and products. The July 16, 2014, inspection found that the facility’s standard operating procedures did not contain accurate information on safety systems and how they worked. The facility’s PHA failed to address many issues in the plant. In addition, employees were not trained in changes to these processes, and inspections and equipment testing were not completed as scheduled.
Here is a breakdown of the citations:
PLEASE NOTE: these citations are NOT the final settlement and some are BEFORE the employer’s informal conference. They are shared as a learning tool to show what types of issues OSHA and EPA are finding in their PSM/RMP inspections. I have scrubbed all company information from these postings as this is NOT about any one company, but rather a trend of issues that continue to be found by OSHA and EPA.
Citation 1 Item 1
Type of Violation: Serious; $5,500
29 CFR 1910.119(d)(2)(i)(C): Information concerning the technology of the process shall include at least the following:
Maximum intended inventory
- The employer’s process safety information (PSI) did not include an accurate maximum intended inventory for the formaldehyde process including formaldehyde plant 1 and plant 2.
- The employer’s process safety information (PSI) did not include an accurate maximum intended inventory for the resin process including the Kl kettle and K3 kettle.
Citation 1 Item 2
Type of Violation: Serious; $5,500
29 CFR 1910.119(d)(2)(i)(D): Information concerning the technology of the process shall include at least the following:
Safe upper and lower limits for such items as temperatures, pressures, flows or compositions
- The employer’s process safety information (PSI) did not include the safe upper and lower limits for formaldehyde plant 2 which included, but was not limited to, the following: converter temperature, converter exit gas temperature, converter pressure, heat transfer fluid (HTF) flow, methanol flow, methanol volume percent, oxygen concentration, HTF condenser water level, blower oil temperature, blower exit air temperature, blower exit air pressure, blower oil pressure, HTF pressure, absorber levels, and formaldehyde storage tank levels.
Citation 1 Item 3a
Type of Violation: Serious; $5,500
29 CFR 1910.119(d)(3)(i)(H): Information pertaining to the equipment in the process shall include:
Safety systems (e.g. interlocks, detection or suppression systems)
- The employer’s process safety information (PSI) was not complete and did not include accurate information on the safety interlocks for formaldehyde plant 2.
Citation 1 Item 3b
Type of Violation: Serious; Grouped
29 CFR 1910.119(f)(1)(iv): The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements:
Safety systems and their functions
- The employer’s Formaldehyde Plant 2 Standard Operating Procedures (Revision #3) did not include accurate information on the plant safety interlocks, and safety system process controls and operating conditions for formaldehyde plant 2.
Citation 1 Item 4
Type of Violation: Serious; $5,500
29 CFR 1910.119(e)(3)(iii): The process hazard analysis shall address: Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors)
- The employer’s 2010 revalidation PHA for the No. 2 Formaldehyde Plant did not address all engineering controls applicable to the hazards identified in the process hazard analysis such as, but not limited to, the following safeguards:
- high oxygen concentration alarm,
- low oxygen concentration alarm,
- high-high oxygen concentration interlock,
- high-high-high oxygen concentration interlock,
- lowlow oxygen concentration interlock,
- high methanol volume percent alarm,
- high-high methanol volume percent interlock,
- high vaporizer outlet temperature alarm,
- low vaporizer outlet temperature alarm,
- low-low vaporizer outlet temperature interlock,
- high converter catalyst bed temperature alarm,
- highhigh converter tube hot spot temperature/high average tube hot spot temperature interlock,
- two highhigh converter tube hot spot temperature interlock,
- high-high converter hot spot temperature/temperature rate of rise interlock,
- high converter exit gas temperature alarm,
- high-high converter exit gas temperature interlock,
- high-high-high converter exit gas temperature interlock,
- high converter pressure alarm,
- low converter pressure alarm,
- high-high converter pressure interlock,
- lowlow converter pressure interlock,
- low HTF flow rate to converter alarm,
- low-low HTF flow rate to converter interlock,
- high HTF condenser steam pressure alarm,
- low HTF condenser steam pressure alarm,
- high HTF system pressure alarm,
- low HTF system pressure alarm,
- high-high HTF system pressure interlock,
- high HTF condenser boiler feed water level alarm,
- low HTF condenser boiler feed water level alarm,
- low-low HTF condenser boiler feed water level interlock,
- primary blower failure interlock,
- secondary blower failure interlock,
- high/low methanol flow alarms, and
- low methanol flow interlock
Citation 1 Item 5
Type of Violation: Serious; $5,500
29 CFR 1910.119(e)(3)(iv): The process hazard analysis (PHA) shall address: Consequences of failure of engineering and administrative controls:
- The employer’s 2010 revalidation PHA for the No. 2 Formaldehyde Plant did not address the consequences of failure of the plant rate reduction interlock for the secondary blower #4 to reduce methanol flow to 7.0 gallons per minute.
- The employer’s 2010 revalidation PHA for the No. 2 Formaldehyde Plant did not address the consequences of failure of engineering controls such as, but not limited to, the following safeguards:
- high oxygen concentration alarm,
- low oxygen concentration alarm,
- high-high oxygen concentration interlock,
- high-high-high oxygen concentration interlock,
- low-low oxygen concentration interlock,
- high methanol volume percent alarm,
- high-high methanol volume percent interlock,
- high vaporizer outlet temperature alarm,
- low vaporizer outlet temperature alarm,
- low-low vaporizer outlet temperature interlock,
- high converter catalyst bed temperature alarm,
- high-high converter tube hot spot temperature/high average tube hot spot temperature interlock,
- two high-high converter tube hot spot temperature interlock,
- high-high converter hot spot temperature/temperature rate of rise interlock,
- high converter exit gas temperature alarm,
- high-high converter exit gas temperature interlock,
- high-high high converter exit gas temperature interlock,
- high converter pressure alarm,
- low converter pressure alarm,
- high-high converter pressure interlock,
- low-low converter pressure interlock,
- low HTF flow rate to converter alarm,
- low-low HTF flow rate to converter interlock,
- high HTF condenser steam pressure alarm,
- low I-ITF condenser steam pressure alarm,
- high HTF system pressure alarm,
- low HTF system pressure alarm,
- high-high HTF system pressure interlock,
- high HTF condenser boiler feed water level alarm,
- low HTF condenser boiler feed water level alarm,
- low-low HTF condenser boiler feed water level interlock,
- primary blower failure interlock,
- secondary blower failure interlock,
- high/low methanol flow alarms, and
- low methanol flow interlock
Citation 1 Item 6a
Type of Violation: Serious; $5,500
29 CFR 1910.119(e)(5): The employer shall establish a system to promptly address the team’s findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions:
- The employer did not document the resolutions and develop a written schedule of when the 177 actions were to be completed for the 1999 revalidation PHA of No. 2 Formaldehyde Unit.
- The employer did not document the resolutions with completion dates and develop a written schedule with target dates as to when the 18 action items were to be completed for the 1996 initial PHA for Formaldehyde Plant #2.
Citation 1 Item 6b
Type of Violation: Serious; Grouped
29 CFR 1910.119(e)(7): Employers shall retain process hazards analyses and updates or revalidations for each process covered by this section, as well as the documented resolution of recommendations described in paragraph (e)(5) of this section for the life of the process:
- The employer did not retain the documented resolution of recommendations for the 2006 revalidation PHA for No. 2 Formaldehyde Unit.
Citation 1 Item 7
Type of Violation: Serious; $5,500
29 CFR 1910.119(f)(1)(ii)(A): The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements:
Operating limits: Consequences of deviation:
- In formaldehyde plant 2, the Formaldehyde Plant 2 Standard Operating Procedures (Revision #3) did not address consequences of deviation, including those affecting the safety and health of employees.
Citation 1 Item 8
Type of Violation: Serious; $5,500
29 CFR 1910.119(j)(2): Written procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment:
- In the formaldehyde plant 2 and resin kettle K-1/1(-3 processes/units, the employer did not establish and implement written procedures to maintain the on-going integrity of piping systems including the replacement of process piping, weld repairs of process piping, use of temporary clamps on process piping, and documenting the details of the associated pipe replacement or repairs.
- In the formaldehyde plant 2 and resin kettle K-1/1(-3 processes/units, the employer did not establish and implement written procedures to maintain the on-going integrity of piping systems including welders performance qualifications.
- In the formaldehyde plant 2 and resin kettle K-1/K-3 processes/units, the employer did not establish and implement written procedures to maintain the on-going integrity of piping systems including criteria for resolving anomalous inspection data related to thickness growth.
- In the formaldehyde plant 2 and resin kettle K-1/lC-3 processes/units, the employer did not establish and implement written procedures to maintain the on-going integrity of piping systems including quality assurance criteria for inspecting and examining welds.
Citation 1 Item 9
Type of Violation: Serious; $5,500
29 CFR 1910.119(j)(4)(ii): Inspection and testing procedures shall follow recognized and generally accepted good engineering practices:
- On piping circuit #050894-04, “HCHO from Storage to Truck Loading Piping System” located in the formaldehyde plant 2 process/unit, the employer did not follow recognized and generally accepted good engineering practices (RAGAGEP) when the weld repair that was performed on or about October 4, 2013, for a leak on au existing weld was not authorized by the authorized piping inspector prior to its commencement.
- On piping circuit #050894-04, “HCHO from Storage to Truck Loading Piping System” located in the formaldehyde plant 2 process/unit, the employer did not follow recognized and generally accepted good engineering practices (RAGAGEP) when the weld repair that was performed on or about October 4, 2013, for a leak on an existing weld was not approved by the authorized piping inspector after the repairs had been completed.
Citation 1 Item 10
Type of Violation: Serious; $5,500
29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers’ recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience:
- In the formaldehyde plant 2 process/unit, the Servomex oxygen analyzer, tag number OIC-201, was not calibrated and inspected weekly according to the employer’s calibration schedule during the months of September through November, 2014.
Citation 1 Item 11
Type ofViolation: Serious; $5,500
29 CFR 1910.119(1)(3): Employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process shall be informed of, and trained in, the change prior to start-up of the process or affected part of the process:
- The employer did not ensure that operators and maintenance employees in the formaldehyde plant 2 process and other process safety management covered areas of the facility were trained in the changes prior to the start-up of the affected part of the process including, but not limited to, the following management of changes (MOC’s):
- MOC ID 119-014, Plant #1 Shutdown Interlock Upgrade;
- MOC ID 074-014, SOP Revisions to Plant # 1 and Plant #2 Clarify 2 Min Purge and to Assure #5 Blower Isolation Valve is Closed Anytime #5 Blower Shuts Down;
- MOC ID 090-014, #2 Plant Make Up Water Piping;
- MOC ID 091-014, #2 Plant Make Up Water Piping X2;
- MOC ID 099-014, Provide Glycol Cooling to Top of #2 Absorber;
- MOC ID 092-14, Change in Personnel Maintenance;
- MOC ID 066-14, Blower 3 Boot Replacement;
- MOC ID 155-13, 3 Soft Patches on the HCHO Kettle Charge Line;
- MOC ID 106-13, Run #2 and #4 Bowers Only; and
- MOC ID 114-013, Automate #2 Oxidizer to the DCS
Citation 2 Item 1a
Type of Violation: Other-than-Serious; $0.00
29 CFR 191O.119(m)(4)(iv): A report shall be prepared at the conclusion of the investigation which includes at a minimum:
The factors that contributed to the incident
- In formaldehyde plant 2, the incident investigation report for Incident Report ID 516831 which involved the tripping of blower 4 with no reduction of the methanol flow rate to 7.0 gallons per minute on or about April 24, 2014, and which was closed on or about July 7, 2014, did not include all of the factors that contributed to the incident.
Citation 2 Item 1b
Type of Violation: Other-than-Serious; Grouped
29 CFR 1910.119(m)(4)(v): A report shall be prepared at the conclusion of the investigation which includes at a minimum:
Any recommendations resulting from the investigation
- In formaldehyde plant 2, the incident investigation report for Incident Report ID 516831 which involved the tripping of blower 4 with no reduction of the methanol flow rate to 7.0 gallons per minute on or about April 24, 2014, and which was closed on or about July 7, 2014, did not include any recommendations or corrective actions.
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