The Sequence of Events Model This is a simple, linear cause and effect model where accidents are seen as the natural culmination of a series of events or circumstances that occur in a specific and recognizable order. A chain often represents the model with a weak link or a series of falling dominos. This model…...
Respondent owned and operated the a chemical manufacturing facility. On September 8-11, 2014, EPA Region 6 conducted an unannounced, onsite CAA 40 C.F.R. Part 68 and Section 112(r) Partial Compliance Evaluation of the Facility. The faility’s RMP lists three covered processes subject to Program 3 requirements. The regulated flammable substances that are held above the…...
Respondent owns a Utilities Plant that maintains the support of steam, refrigeration, compressed air, cooling and process water; wastewater treatment, electricity, and natural gas for a chemical manufacturing complex. The Utilities Plant includes methanol storage and ammonia storage tank operations and distribution systems. Respondent produces, processes, stores, or handles up to a maximum of 51,180,000 pounds…...
Respondent owns and operates a global technology and specialty materials company operating in the production of vinyl acetate. Respondent operates the Facility in part to produce vinyl acetate in a reactor process. Vinyl acetate is identified at 40 C.F.R. Part 68.130 as a toxic regulated substance with a threshold quantity of 15,000 pounds. Respondent produces, stores,…...
KMCL has noted that OSHA has been very aggressive in its enforcement efforts and in seeking large penalties over the last several months. As described below, the initiatives the agency has recently announced signal that this intensity will continue to ratchet up over the coming months and likely beyond. As a result, employers should consider…...
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The Environmental Protection Agency (EPA) is amending its hazard categories in the regulations (40 CFR part 370) for reporting under Sections 311 and 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA) due to the changes in the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS). OSHA’s HCS was revised in 2012…...
Respondent owned and operated a chemical plant where regulated substances and other extremely hazardous substances are produced, processed, stored, and handled, and from which an accidental release could occur. Within the Facility, at the time of the incidents described herein, Respondent used and produced butadiene, chlorine, pentane, sodium hydroxide, hydrochloric acid, toluene, 1 ,4-dichloro-2-butene, 3,4-dichloro-1…...
This week OSHA issued a willful violation for Lockout/Tagout (LOTO) deficiencies involving a spray dryer absorber (SDA) at a power generation plant. What is shocking is the fact that a 46-year-old worker lost four (4) fingers on his right hand in the December 2015 accident. During the course of its investigation into the December 2015 accident, OSHA…...
It appears OSHA is getting serious about 1910.106(e)(2)(ii)(b)… 1910.106(e)(2)(ii) “Containers.” flammable liquids shall be stored in tanks or closed containers. 1910.106(e)(2)(ii)(a) Except as provided in subdivisions (b) and (c) of this subdivision, all storage shall comply with paragraph (d) (3) or (4) of this section. 1910.106(e)(2)(ii)(b) The quantity of liquid that may be located outside of an inside storage…...
This posting is a demonstration as to how OSHA (State of IN OSHA) can/will issue citations against BOTH the host facility and it’s contractor for the same OSHA violations. In this case, the contractor doing the work, did so using TAGOUT without any additional measures that would make “tagout” equally effective as “lockout” (e.g. Tag…...
