Could it be? IN-OSHS issues a PSM citation

This is the first and only PSM citation that I have seen from IN-OSHA. It is a single violation cited for contractor safety, and it appears it may have been related to an incident involving a contractor working on an Ammonium hydroxide tank. I am NOT certain about this, just trying to read between the lines in the citations.

However, as rare the IN-OSHA PSM citation is, the one that really caught my eye was the citation that the company, which is the manufacturer of the Ammonium Hydroxide, “did not identify the vapors released from this liquid as being flammable and the upper/lower flammability range for this vapor was not provided on the SDS“.

FINALLY, a manufacturer is being held accountable for a poorly written Safety Data Sheet (SDS). I have written several articles over the past few years, expressing my frustration with the poor quality of many SDSs. I have even explicitly written about flammable liquid SDSs, not providing the LEL/UEL range. So it is refreshing to see OSHA, albeit a state-run plan, taking issue with the quality of an SDS.

Here are the citations:

Safety Order 1 Item 1
Type of Violation: Serious; $7,000
29 CFR 1910.119(h)(2)(ii): The employer did not inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor’s work and the process:

Ammonium hydroxide tanks – Contract employees were exposed to ammonia gas, chemical and thermal burns while they replaced valves and cut holes into the ammonium hydroxide tank. The contractor had not been informed of the hazards of the ammonium hydroxide prior to working on the tank.

Safety Order 1 Item 2
Type of Violation: Serious; $2,400
29 CFR 1910.1200(g)(5): The chemical manufacturer, importer or employer did not ensure that the information provided accurately reflects the scientific evidence used in making the hazard classification:

Office – The safety data sheet (SDS) for ammonium hydroxide manufactured on site did not identify the vapors released from this liquid as being flammable . The upper/lower flammability range for this vapor was not provided on the SDS.

Safety Order 1 Item 3
Type of Violation: Serious; $7,000
29 CFR 1926.352(i): Drums, containers, or hollow structures which have contained toxic or flammable substances were not, before welding, cutting, or heating was undertaken on them, either be filled with water or thoroughly cleaned of such substances and ventilated and tested:

Ammonium hydroxide tanks – Contract and full time employees were exposed to ammonia gas and burns while cutting holes through the top of a metal storage tank of ammonium hydroxide.

Source: https://www.in.gov/dol/files/1794156-Alexander-Chemical-Corporation-Over-10k.pdf

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