Another OSHA PSM citation with some interesting citations. In this one, the company:
- was using Global FM Engineering Data Sheets as their RAGAGEP(s) for Rupture Disk sizing and Fire Protection, but failed to list these data sheets in their PSI as officially adopted RAGAGEPs.
- had multiple pieces of equipment on the system that were not tagged, marked or labeled with information to identify equipment on the system that was represented on the company’s P&IDs
- had approximately 10 instances occurred where equipment documented on the P&IDs were not installed on the PSM covered systems
- had approximately 3 instances occurred where equipment on the PSM covered systems were not drawn in the correct location on the P&IDs
- used a state code to design its secondary containment but was not listed as the design RAGAGEP in the PSI
OSHA cited the plastics resin manufacturer for one willful, five serious and one other-than-serious safety violation after it opened an investigation under the national emphasis program for process safety management. Here is a breakdown of the citations:
Citation 1 Item 1
Type of Violation: Serious; $5,000
29 CFR 1910.119(d)(3)(i)(B): The employer’s piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process.
On or about 11/24/2015, the employer’s piping and instrument diagrams for the outdoor formaldehyde unloading/storage unit and the Resin Building Kettle 19 unit were not accurate and did not represent equipment that was existing and was part of the process when:
a) Multiple pieces of equipment on the system, such as but not limited to; valves, strainers, flexible connections, temperature/pressure gages, and temperature/pressure sensors, were not tagged, marked or labeled with information to identify equipment on the system that was represented on the company’s P&ID drawings.
b) Approximately 21 instances occurred where equipment on the PSM covered systems were not documented on the company’s P&ID, such as but not limited to;
valves,
goose necked vapor release lines,
temperature sensors,
temporary temperature and pressure devices,
flexible lines,
antifoam/dry additives equipment,
piping lines between Kettle 19 and Condenser 19,
a line blind, and
a temporary valve.
c) Approximately 10 instances occurred where equipment documented on the company’s P&ID were not installed on the PSM covered systems, such as but not limited to:
pressure gages,
valves,
a deadend pipe section and
a section of piping from the truck loading area drawn to a non-existent planned storage tank.
d) Approximately 3 instances occurred where equipment on the PSM covered systems were not drawn in the correct location on the company’s P&ID, such as but not limited to;
a line to the sewer from Scale Tank #5 drawn as blanked and disconnected when it was actually connected on the system;
finished molten resin tanks (T14, T27, T28, T52) were drawn in the wrong locations; and
a drawn 4-way cross section of 4″ pipe was actually a 4″ Tee section with a 3/4″ perpendicular line downstream from the Tee.¥¥
e) Approximately 7 instances occurred where equipment on the P&ID was identified with the wrong symbol for the part or the symbol was not designated on P&ID legend, such as but not limited to:
strainers,
valves,
lines entering a building from outdoor unloading system, and
lines leaving receiver tank 19 didn’t designate the adjoining P&ID sheet.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 2a
Type of Violation: Serious; $5,000
29 CFR 1910.119(f)(3): The operating procedures were not reviewed to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities and the employer did not certify annually that the operating procedures were current and accurate.
a) On or about 08/27 /2015, the employer had not annually reviewed or certified that operating procedures were current and accurate such as but not limited to; “Outside Work Crews Working In Or On Company Facilities or Grounds” standard safety procedure #6, “Watch Tour Instruction” for the night watchman, Control System Operations Manual for the tank farm and Resin Kettle Log Batch/Formula operating procedures.
b) On or about 11/19/2015, the employer did not review the written operating procedures for formaldehyde unloading when a management of change (MOC) procedure required a temporary change by “Keep Blocking valve open at vapor return hose for Formaldehyde Unloading” as part of the carbon canister (scrubber) MOC procedure (W/O No. 20156362).
Citation 1 Item 2b
Type of Violation: Serious;
29 CFR 1910.119(l)(5): A change covered by this paragraph resulted in a change in the operating procedures or practices required by paragraph (f) of this section, and such procedures or practices were not updated accordingly:
On or about 11/19/2015, the written operating procedures for the formaldehyde unloading from truck tankers was not updated accordingly when a temporary management of change (MOC) procedure affected the Chem Unloader employee’s operating procedures.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 3a
Type of Violation: Serious; $7,000
29 CFR 1910.119(l)(2)(ii): The management of change procedures did not assure that the impact of changes on safety and health were addressed prior to any change. The employer’s management of change (MOC) procedures did not assure that the impact of changes on safety and health were addressed prior to any change when:
a) On or about 10/26/2015, a temporary MOC procedure to install temperature and pressure sensors in a formaldehyde line to Scale 15 was not reviewed by the safety and health department and did not specifically address the potential impact of changes on safety and health.
b) On or about 11/19/2015, a temporary MOC procedure to keep a blocking valve open during formaldehyde unloading was not reviewed by the safety and health department and did not specifically address the potential impact of changes on safety and health.
c) On or about 12/01/2015, a permanent MOC procedure to relocate formaldehyde carbtrol canister was not reviewed by the safety and health department and did not specifically address the potential impact of changes on safety and health.
Citation 1 Item 3b
Type of Violation: Serious
29 CFR 1910.119(1)(2)(iv): The management of change procedures did not assure that the necessary time period for the change was addressed prior to any change.
The employer’s management of change (MOC) procedures did not assure that the necessary time period for the changes were addressed prior to any change when:
a) On or about 11/19/2015, a temporary MOC procedure to keep a blocking valve open during formaldehyde unloading did not include an expected completion date or anticipated time period for the change.
b) On or about 12/01/2015, a permanent MOC procedure to relocate formaldehyde carbtrol canister in the formaldehyde unloading area did not include an expected completion date or anticipated time period for the change.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 4a
Type of Violation: Serious; $5,000
29 CFR 1910.119(m)(5): The employer shall establish a system to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions shall be documented.
On or about 08/27/2015, the employer did not establish a system to resolve the incident report findings and recommendations when:
a) An incident investigation for a release of approximately 5.5 gallons of formalin which occurred on or about 05/16/2013 determined the release was due to a leaking flange. The incident investigation system did not address corrective actions, such as but not limited to mechanical integrity inspections to minimize or eliminate additional releases from leaking flanges or similar equipment.
b) An incident investigation for a release of approximately 20 gallons of formalin which occurred on or about 06/25/2014 determined the release was due to the pin used to secure the line’s cam-lock fitting was not engaged. The incident investigation system did not address corrective actions, such as but not limited to operating procedures reviews or updates or mechanical integrity quality assurance to minimize or eliminate additional misuses of the equipment.
Citation 1 Item 4b
Type of Violation: Serious
29 CPR 1910.119(m)(6): The Incident Investigation report was not reviewed with all affected personnel whose job tasks were relevant to the incident findings including contract employees where applicable.
On or about 08/27 /2015, the employer did not review with all affect personnel whose job tasks are relevant to the incident findings when:
a) An incident investigation for a release of approximately 5.5 gallons of formalin which occurred on or about 05/16/2013 determined the release was due to a leaking flange.
b) An incident investigation for a release of approximately 20 gallons of formalin which occurred on or about 06/25/2014 determined the release was due to the pin used to secure the line’s cam-lock fitting was not engaged.
c) An incident investigation for a release of approximately 200-500 gallons of formalin which occurred on or about 01/03/2015 determined the release was due to a leaking valve gasket at the tank farm.
d) An incident investigation for a release of approximately 5 gallons of formalin which occurred on or about 09/22/2015 determined the release was due to an unseated valve gasket at the tank farm.
Citation 1 Item 5
Type of Violation: Serious; $5,000
29 CFR 1910.119(n): The emergency action plan did not include procedures for handling small releases.
On or about 08/27 /2015, the employer’s Emergency Response Plan did not include distinctions of small versus large releases of toxic chemicals such as formaldehyde nor did it include procedures for handling small release from the PSM covered system including, but not limited to, the Outdoor Formaldehyde Unloading station or the indoor reactor Kettles and associated equipment.
Citation 2 Item 1
Type of Violation: Willful; $55,000
29 CFR 1910.119(o)(1): The employer did not certify that they have evaluated compliance with the provisions of this section at least every three years:
On or about 08/27/2015, the employer did not conduct or certify, at least every three years, that the company had evaluated compliance with the provisions of this section. The employer’s most recent audit was a document titled “Process Safety Management Audit” dated August of 201O; the document was not a compliant compliance audit.
Citation 3 Item 1
Type of Violation: Other-than-Serious; $0.00
29 CFR 1910.119(d)(3)(i)(F): The employer did not include the process safety information of the design codes and standards which were employed.
On or about 08/27/2015, the employer did not include all the process safety information of design codes and standards when:
a) API 2000 was employed by the company to design and maintain the emergency pressure relief systems.
b) FM Global standard and equations were employed by the company to size rupture discs.
c) Foxboro, Beckman and Asco safety instrumentation systems and emergency shutdown systems were employed by the company to read and regulate equipment temperatures and pressures.
d) FM Global standard was employed by the company to design and maintain the fire detection and suppression systems.
e) NFPA 12A standard was employed by the company to design and maintain the halon fire suppression system.
f) Wisconsin SPS 310 standard was employed by the company to design the dike system.
g) Un-interruptable Power Supply (UPS) standard was employed by the company to size, design and maintain the DCS control systems.
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