OSHA initiated an inspection on Nov. 21, 2014, as a follow-up to its May 30, 2013, inspection. Company received two failure-to-abate notices for hazards for which the employer had been cited previously: not maintaining process equipment and not adequately addressing the potential impact of a vapor cloud explosion on an occupied temporary trailer. Additionally, OSHA found two repeat violations involving workers performing service on a compressor without locking it out. The company also did not ensure that the written process safety information included all the necessary information pertaining to the equipment. One serious violation was issued for not conducting management of change reviews as required. Here is the breakdown of the citations:
Citation 1 Item 1
Type of Violation: Serious; $3,080
29 CFR 1910.119(1)(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) A temporary wooden trailer was added to the facility for use as an office by the workers without a management of change review.
b) Employee and management changes were made without a management of change review. The plant manager, !st shift lead operator, and the 2nd shift lead operator no longer work at the plant. This change occurred in the same time period.
Citation 1 Item 2
Type of Violation: Repeat; $6,160
29 CFR 1910.147(c)(4)(i): Procedures were not utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:
a) Compressor room – Employees were performing service to Compressor #2 without locking out the electrical source at 208v.
Citation 2 Item 1
Type of Violation: Repeat; $6,160
29 CFR 1910.119(d)(3)(i)(B): ): Process safety information pertaining to the equipment in the process did not include piping and instrumentation diagrams (P&IDs):
a) Fill plant – The employer did not ensure that the written process safety information included all the necessary information pertaining to the equipment in the process when pressure indicator, PI 211 & PI 212, identified in the P&ID Sheet #B 19 was not present in the plant.
b) Rack R-13 – The employer did not ensure that the written process safety information included all the necessary information pertaining to the equipment in the process in that pressure reducing block and a pressure indicator were not represented on the P&ID Sheet #B21.
c) Rack R-15 – 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 before check valve Y2557J & Y258J, is not represented on the P&ID; existing valves X257J, X259J, X260J are not the same configuration as represented in P&ID; the P&ID identifies pressure indicator PI262 and flash arrester where there is no pressure indicator in plant. See Sheet #B22.
d) Rack R-14 – The employer did not ensure that the written process safety information included all the necessary information pertaining to the equipment in the process where a flash arrestor on the P &ID was not present in the plant; the configuration of the valves X252J, X253J, X254J on the P&ID is not representative of the existing valves in the plant; and an existing valve at the end of the fill line which is not present on the P&ID. See Sheet #B22.
Company was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.119( d)(3)(I)(B), which was contained in OSHA inspection number 908983, citation number I, item number 5, and was affirmed as a final order on (date).
Citation 1 Item 6
29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting:
a) Establishment – The 2014 PHA did not address potential acetylene vapor cloud explosion scenarios and the associated over pressure impact on an occupied temporary office trailer located approximately 100 ft feet from the plant.
Violation observed on or about 12/5/2014.
Additional Penalty: $21,000.00
Citation 1 Item 15
29 CFR 191O.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:
b) Establishment – cylinder charging room – Pigtails for small cylinders (B & MC) were used to fill cylinders with acetylene gas while the reinforcement cover was pinched and frayed.
Violation observed on or about 12/3/2015.
Additional Penalty: $ 21,000.00