A manufacturer of custom-sized resin balls used as flotation devices in the petroleum and fracking industries failed to protect its employees from the risk of death or serious injury from potential fires, explosions and other hazards by not providing and using mandatory safeguards. Officials from OSHA began inspecting the plant in October 2014, in response to complaints. Inspectors identified 48 violations of workplace safety and health standards, resulting in $105,200 in proposed fines. The ball manufacturing process requires the storage and use of up to 1,900 pounds of a flammable formaldehyde solution. In addition, inspectors found the presence of combustible resin dust; flammable liquids improperly stored and transferred; no audible fire alarm and fire-suppression system; and locked and obstructed exit routes.
Citation 1 Item 1
Type of Violation: Serious; $2,800
OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which is free from recognized hazards that were likely to cause death or serious physical harm to employees in that employees were exposed to phenol-formaldehyde resin dust fire, deflagration and explosion hazards:
- On or about October 3, 2014, outside in the yard, the ductwork for the Pangborn dust collection system was not grounded to prevent any static electricity generated by the movement of phenol formaldehyde resin dust over the metal ducts from becoming a potential ignition source.
- On or about October 3, 2014, outside in the yard, the Pangborn dust collector itself was not grounded to prevent the generation of static electricity from becoming a potential ignition source.
- On or about October 3, 2014, in the basement lathe area and outside in the yard, sparks generated by the metal chuck of the lathe striking the metal clamps that secured the phenol-fonnaldehyde resin balls during shaping, could travel into the Pangborn dust collection system and ignite the dust. The employer’s failure to control this ignition source has resulted in a history of fires at this facility.
- On or about October 3, 2014, outside in the yard, ductwork for the Pangborn dust collection system had 90 degree angle bends where phenol-formaldehyde dust could accumulate and potentially ignite.
- On or about October 3, 2014, outside in the yard, the ducting next to the dust collector was supported by bricks loosely stacked to support the duct, resulting in breaks in the ductwork, leading to the potential release of phenol-fonnaldehyde resin dust.
- On or about October 3, 2014, outside in the yard, explosion relief venting was not provided for the Pangborn dust collection system to prevent a fire in the collector from traveling back into the building through the ductwork.
**A sample collected from the waste collection drum of the Pangborn dust collector showed a Kst value of 29.57 bar meters per second.
Among other methods feasible and acceptable means of abatement include:
- Follow the guidelines under chapter 6.1.1 of the National Fire Protection Standard (NFPA) 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate. Solids edition 2013 for completing an evaluation of dust flash fire and explosion hazards for the facility and process equipment.
- Follow the guidelines under section 7.1.4.1 ofNFPA 654 Standard (NFPA) 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids edition 2013edition, for the design of explosion protection for the Pangborn Dust collector.
- Follow the guidelines under section 7.1.6.1 and 7.1.7 of the NFPA Standard (NFPA) 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids edition 2013, which requires isolation devices to be provided to prevent deflagration propagation between pieces of equipment connected by ductwork upstream to the work area.
- Follow the guidelines of 10.2.1 through 10.2.10 of NFPA 654 for designing a fire protection system including a detection system for the dust collection system in the basement used to collect the dust generated from machining of resin balls.
- Follow the guidelines of Chapter 9 ofNFPA 654 for Ignition Sources.
- Follow the guidelines ofNFPA 654 section 9.3.2.3 for bonding and grounding.
Citation 1 Item 2
Type of Violation: Serious; $2,000
29 CFR 1910.106(h)(4)(i)(d): The storage of flammable liquids in containers was not in accordance with the applicable provisions of paragraph (d) of this section:
(a) On or about October 3, 2014, in the facility, three (55) gallon drums of a 37% solution of formaldehyde, a Class 4 flammable liquid were stored on the first floor in a room that did not meet the requirements for an inside storage room as outlined in 1910.106(d)(4)(i).
Citation 1 Item 3
Type of Violation: Serious; $2,800
29 CFR 1910.106(h)(6)(ii)(d): Processing plants were not protected by an approved automatic sprinkler system or equivalent extinguishing system:
(a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins for casting into custom sized resin balls. The formaldehyde being used to make the resin was a 37% solution classified as a Class 4 flammable liquid. The processing area on the second floor of this building was not equipped with an approved automatic sprinkler system or equivalent system.
Citation 1 Item 4
Type of Violation: Serious; $2,800
29 CFR 1910.106(h)(6)(iii): An approved means for prompt notification of fire to those within the plant and any public fire department available was not provided:
(a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins for casting into custom sized resin balls. The facility handles and stores a 37% solution formaldehyde, a Class 4 flammable liquid in 55 gallon drums. An alarm system to notify workers in the plant and for contacting the local fire department had not been established.
Citation 1 Item 5
Type of Violation: Serious; $2,000
29 CFR 1910.106(h)(7)(i)(a): Precautions shall be taken to prevent the ignition of flammable vapors:
(a) On or about October 14,2014, on the first floor, for an employee drawing formaldehyde under vacuum from a plastic 55 gallon drum through a metal suction fill pipe into kettle #3. The metal suction fill pipe was not grounded during transfer to prevent static electricity from being generated.
Citation 1 Item 6
Type of Violation: Serious; $2,800
29 CPR 1910.119(c)(1): The employer did not develop a written plan of action regarding the implementation of the employee participation required by 29 CPR 1910.119:
(a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The employer had not developed a written plan of action for employee participation in process safety management.
Citation 1 Item 7
Type of Violation: Serious; $2,800
29 CFR 1910.119( d)(2)(i): Process safety information pertaining to the technology of the process did not include the elements specified in29 CFR 1910.1 19(d)(2)(i)(A) through (E):
(a) On or about October 3, 2014, at the facility, the employer failed to compile process safety information pertaining to the technology of the process used to manufacture phenol-formaldehyde resins including but not limited to:
- A block flow diagram or simplified process flow diagram
- Maximum intended inventory for formaldehyde
- Safe upper and lower limits for operating under vacuum pressure for kettle #3
- Safe upper and lower limits for operating under vacuum pressure and temperature for kettle #4
- An evaluation of the consequences of deviations, including those affecting the safety and health of employees
Citation 1 Item 8
Type of Violation: Serious; $2,800
29 CFR 1910.119(d)(3)(i): Process safety information pertaining to the equipment in the process did not include the elements specified in 29 CFR 1910.119(d)(3)(i)(A) through (H):
(a) On or about October 3, 2014, at the facility, the employer failed to compile process safety information pertaining to the technology of the process used to manufacture phenol-fonnaldehyde resins including but not limited to:
- Materials of construction for kettles #3 and#4
- Materials of construction for the packing material installed on the primary vacuum pump
- Piping and instrument diagrams
- Electrical classification
- Design codes and standards employed
Citation 1 Item 9
Type of Violation: Serious; $2,800
29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complied with recognized and generally accepted good engineering practices:
a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The faceplate identifying the manufacturer, the vessel, and design specifications was missing. The faceplate is required to be present on the vessel as required under such as, but not limited to API 620-2008, “Design and Construction of Large, Welded, Low-Pressure Storage Tanks, section 1.1.
(b) On or about October 3, 2014, at the facility, kettle #3 and kettle #4 was designed and built as a pressure vessel by lhe manufacturer. They were modified after manufacturing and hydrostatic testing to operate under vacuum pressure in this production process. The employer did not subject the vessels to pressure and vacuum testing after this alteration as required under such as, but not limited to API 572-
2009, “Inspection Practices for Pressure Vessels,” section 9.7.2.
(c) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting resin into custom sized balls. The steam and vacuum piping including valves throughout the processing equipment were not labeled as to their identity and the direction of flow using the requirements outlined in such as, but not limited to ASME Al3.1-2007, “Scheme for the Identification of Piping Systems”.
(d) On or about October 3, at lhis facility, for employees manufacturing phenol-fonnaldehyde resins and casting resin into custom sized balls. Kettles #3 and #4 were not equipped with safe valves to relieve pressure, if over pressurization occurred in these low pressure reactors during this exothermic reaction. The requirement to install pressure-relieving valves and emergency vacuum-reliving valves is
Citation 1 Item 10
Type of Violation: Serious; $2,800
29 CFR 1910.119(e)(1): The employer did not perform an initial process hazard analysis (hazard evalnation) on processes covered by 29 CFR 1910.119:
a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The employer had not performed an initial process hazard analysis for the storage of the formaldehyde and the process of manufacturing the phenolformaldehyde resins. The employer is covered under 1910.119 because more than 1,000 1bs. of formaldehyde were observed in storage on the first floor of the building on October 3, 2014.
Citation 1 Item 11
Type of Violation: Serious; $2,800
29 CPR 1910.119(f)(1): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and which addressed elements listed in 29 CPR 1910.119(f)(1)(i) through (f)(1)(v):
(a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The employer did not develop and implement operating procedures for operating phases including initial startup, temporary operations, normal operations for kettle #4, emergency shutdown, emergency operations, normal shutdown, and startup following a turnaround, or after an emergency shutdown.
Citation 1 Item 12
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:
(a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The employer had not developed and implemented safe work practices to provide for the control of lockout hazards encountered while employees perform servicing and maintenance on process equipment and opened process equipment to replace valves. The employer is covered under 1910.119 because more than 1,000 1bs. of formaldehyde were observed in storage on the first floor of the building on October 3, 2014.
Citation 1 Item 13
Type of Violation: Serious; $2,800
29 CFR 1910.119(i)(1): The employer did not perform a pre-startup safety review for new facilities and for modified facilities when the modification was significant enough to require a change in the process safety information:
(a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The employer did not perform a pre-startup safety review after the Kinney portable backup vacuum pump was connected to the process. The employer is covered under 1910.119 because they store more than the threshold quantity of 1,000 lbs of formaldehyde on site.
Citation 1 Item 14
Type of Violation: Serious; $2,800
29 CPR 1910.119(j)(2): The employer did.not establish written procedures to maintain the on-going integrity of process equipment:
a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The employer had not established written procedures to maintain the on-going integrity of process equipment used to manufacture the resin such as the two pressure vessels, the steam, water and vacuum piping including the valves, the relief system on the boiler, the emergency shutdown switches for the boiler, the manual steam gauges located on the boiler and in the processing area and the two Kinney vacuum pumps. The employer is covered under 1910.119 because more than 1,000 lbs of formaldehyde were observed in storage on the first floor of the building on October 3, 2014.
Citation 1 Item 15
Type of Violation: Serious; $2,800
29 CFR 1910.119(j)(3):The employer did not train each employee involved in maintaining the ongoing integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee’s job tasks to assure that the employee could perform the job tasks in a safe manner:
a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The employer had not conducted training for employees involved in maintaining the on-going integrity of process equipment used to manufacture the resin such as the two pressure vessels, the steam, water and vacuum piping including the valves, the relief system on the boiler, the emergency shutdown switches for the boiler, the manual steam gauges located on the boiler and in the processing area and the two vacuum pumps. The employer is covered under 1910.119 because more than 1,000 lbs of formaldehyde were observed in
storage on the first floor of the building on October 3, 2014.
Citation 1 Item 16
Type ofViolation: Serious; $2,800
29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:
(a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The employer did not develop and implement an inspection plan for the two pressure vessels as outlined in documents such as but not limited to API 572-2009, “Inspection Practices for Pressure Vessels”, section 6.
(b) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The Weil-McLain low-pressure steam boiler, Boiler EG/PEG-50, was not inspected either internally or externally as required by New York State Industrial Code Rule 4. This steam boiler is used to supply steam to the two reactors that are manufacturing the phenol-formaldehyde resins.
Citation 1 Item 17
Type of Violation: Serious; $2,800
29 CPR 1910.119(l)(1): The employer did not establish written procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process:
(a) On or about October 3, 2014, in the processing area, for the gate valve on kettle #4 used to control steam that was replaced with a flow control Valve, a combination valve and flow control instrument. The employer did not establish written procedures to manage this change in equipment and procedures.
Citation 1 Item 18
Type of Violation: Serious; $2,800
29 CPR 1910.119(n): The employer did not establish an emergency plan for the entire plant in accordance with the provisions of29 CPR 1910.38:
(a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins for casting into custom sized resin balls. The employer did not establish an emergency action plan to address the procedures to follow in the event of a fire and responding to small and large spills of chemicals. The facility handles and stores formaldehyde and phenol in 55 gallon drums. There were
1,118 lbs. of formaldehyde on the site on October 3, 2014. The threshold quantity for formaldehyde requiring coverage under 1910.119 is 1,000 lbs.
(b) On or about December 2014, at the facility, for an employee using a fork lift truck to bring a 55 gallon drum of 2-propoxyethanol ordered by Plastic Maritime Corporation, a separate company that leases space from this employer, into their shared storage space on the first floor. The employer did not establish an emergency action plan to address the procedures to follow in the event of a spill of these
chemicals during transport.
Citation 1 Item 19
Type of Violation: Serious; $2,800
29 CFR 1910.132(a): Protective equipment was not used when necessary whenever hazards capable of causing injury and impairment were encountered:
(a) On or about October 30, 2014, at the facility, for the lathe operator wearing regular clothes, while expected to use a hose to put out a fire in the outside dust collector, if smoke was detected in the lathe room through the ductwork. The employer shall assure that protective clothing protects the head, body and extremities, and consists of the following: foot and leg protection; hand protection; body
protection; eye, face and head protection.
Citation 1 Item 20
Type of Violation: Serious; $1,600
29 CFR 1910.305(g)(1)(iv)(A): Flexible cords and/or cables were used as a substitute for the fixed wiring of a sturcture:
(a) On or about October 14, in the first floor storage area, the Allen Bradley electrical control switch servicing the window mounted wall fan was wired with flexible cord that ran through the exterior wall.
(b) On or about October 27, 2014, an extension cord plugged into a junction box was being used as pennanent wiring to power a Shop-Vac.
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