OSHA cited a paint plant for 26 health violations after a cloud containing flammable vapors was released from the company’s Columbus facility on March 21, 2012. OSHA initiated an inspection under its national emphasis program (NEP) on process safety management (PSM) for covered chemical facilities. Proposed fines total $138,600. The vapor cloud was caused by a copolymer reaction of flammable chemicals when over-pressurization occurred in the equipment. No injuries were reported.
Twenty-five serious safety violations relate to process safety management, including incomplete process safety information lacking maximum intended inventories, materials of construction, and accurate piping and instrument diagrams or design codes and standards. Violations specific to process hazard analyses include failing to address hazards of the process consequences to engineering and administrative control failures. Additionally, the violations include failing to implement written operation procedures and review and certify them annually, train workers on procedures, establish and implement written mechanical integrity and management of change procedures, conduct a compliance audit at least every three years and respond to deficiencies found in compliance audits. A serious violation occurs when there is substantial probability that death or serious physical harm could result from a hazard about which the employer knew or should have known. Here is breakdown of the citations:
Process Safety Information
Maximum Intended Inventory (Serious; $6930
- Six (6) vessels did not have their Maximum Intended Inventory stated (NOTE from me: I have to wonder if this one will stick as I have NEVER seen anything indicating that the MII is to be stated for each vessel, but rather for the entire process. Each vessel will have a Safe Upper Limit for LEVEL, but not a MII – my personal take on this citation)
Materials of Construction (Serious; $6930)
- Material of Construction for a catch tank associated with three process vessels was not defined in the PSI
Design Codes and Standards employed
- Facility could not point to a RAGAGEP used in the construction/design of the open top catch tank associated with three process vessels
Piping & Instrumentation Diagrams (P&IDs) (Serious; $6930)
NO P&ID for the cooling water loop (cooling water in this process would be considered a “critical utility”)
- NO P&ID for presses associated with the process
- Foam tank in process not shown on P&ID
- NO P&ID for the flammable and monomer tank farm and the finished product tank farm
- 16 examples where P&IDs were not updated
Relief System Design (Serious; $6930)
- Facility did not have the design for the emergency vent system on a process vessel
Equipment did not comply with RAGAGEP (Serious; $6930)
- Open top catch tank design did not meet any RAGAGEP
- Process ventilation fans were not rated for HAZLOC
- No U-1 form for a process vessel
- No name-plate on a process vessel (same vessel that did not have a U-1 form)
- No records for pressure vessel modifications (inner cooling coils moved up, two nozzles were changed from 2″ to 3″, three new 3″ connections made to bottom of vessel, sparge rings removed)
Process Hazards Analysis
PHA did not cover all process hazards (Serious; $6930)
- PHA did not address overfilling process vessels with flammable liquids which then flowed to an open top catch tank
- PHA did not address using an organic peroxide catalyst with bronze piping and valves
- PHA did not address a relief valve on the discharged side of a catalyst pump discharging into a catalyst tank rather than to the inlet of the pump
- PHA did not address a relief valve on the discharged side of a monomer pump discharging into a monomer tank rather than to the inlet of the pump
PHA did not address failure of engineering and administrative controls (Serious; $6930)
- the facility replaced two process vessels and the PHA for this change did not address the failure of alarms, interlocks.
- failure of ventilation of process area (mechanical or forgot to turn it on)
PHA did not include Facility Siting (Serious; $6930)
- PHA did not consider the use of vehicles, including powered industrial trucks, in/around the process unit which subjected the process equipment and piping to damage
- PHA did not consider the construction and location of the control room in the process building
PHA did not address Human Factors (Serious; $6930)
- PHA did not address operational and shift turn-over communications, lack of operator response to critical alarms, fatigued operators working double shifts, operator overload during normal operations, emergency operations and emergency shutdown
PHA not updated within 5 years
- the process vessel replacement project PHA was not re-validated within 5 years
Operating Procedures
SOPs did not reflect actual practices (Serious; $6930)
- The actual practice of adding catalyst through catalyst pumps did not reflect the SOP instructions by using the gravity feed system
- Increasing process temperatures above 275F did not reflect what SOP stated
Annual certification of SOPs and review as often as necessary to ensure the SOP reflect actual practice (Serious; $6930)
- ten (10) SOPs (include an operator training manual) were not annually certified
- one SOP did not reflect actual practice
- one SOP did not reflect the proper process temperature
Training
Refresher training not conducted at least every three years (Serious; $6930)
- nine (9) operators operating six (6) kettles not provided refresher training within 3 years
- no training records for the initial training of the nine (9) operators
Mechanical Integrity
Written MI procedures (Serious; $6930)
- no written procedures to maintain the integrity of pressure vessels and storage tanks
- no written procedures to maintain the integrity of process piping and valves
- no written procedures to maintain the integrity of relief devices and vent systems
- no written procedures to maintain the integrity of emergency shutdown systems
- no written procedures to maintain the integrity of sensors, alarms and interlocks
- no written procedures to maintain the integrity of pumps
- no written procedures to ensure that equipment, maintenance supplies and spare parts were suitable for the process
MI Training (Serious; $6930)
- process engineer involved in the MI of process vessels, scale tanks, and storage tanks was not trained in the procedures applicable to his/her duties
- maintenance personnel conducting inspection and testing on process equipment did not receive training on procedures applicable to their work
Equipment not getting inspected (Serious; $6930)
- Process piping components such as ball valves, solenoid valves, and pressure safety valves
- Process controls on a process vessel including Hi-Level alarm, RPM sensor on agitator, reaction temp control, and temp control in secondary condenser vent
Inspections and Tests did not follow a RAGAGEP
- process vessel did not receive an internal inspection, external inspection, nor thickness measurements
- vibration analysis not conducted process equipment
Inspection Documentation
- no inspection records on rupture discs
- no inspection records on effluent piping
- no inspection records on catch tank
- no inspection records on pipe bridges
New construction QA (Serious; $6930)
- bronze valves and pipe used to transfer organic peroxide catalyst
- steam condensate system installed too close to the organic peroxide transfer system
Management of Change
MOCs not done on 3 changes and 17 MOCs had errors or not completed (Serious; $6930)
Auditing
3-year audits not conducted (Serious; $6930)
Findings from the last audit (1995) were not addressed (Serious; $6930)
PPE Hazard Assessments
No certified PPE Hazard Assessment on maintenance employees (Other-than-Serious; $0.00)