OSHA has cited a fireworks manufacturer $116,900 for 25 serious and six other-than-serious safety violations after three workers suffered burns caused by an explosion at the company’s facility in March. The employees were transported to local hospitals, and two were treated for serious burns and released. The third employee, who suffered third-degree burns, was hospitalized for approximately 20 days. The serious violations relate to hazards associated with the improper handling of explosives, improper storage of flammable liquids and a lack of ventilation in rooms where the liquids are used. Several violations relate to process safety management include failing to address safety hazards, provide engineering controls, train workers on emergency shutdown procedures, implement an effective lockout/tagout program to control hazardous energy, guard machines and repair electrical deficiencies. Here is a break down on the citations:
Flammable Liquids
- Inside flammable liquids storage room did not meet fire resistance requirements, did not have containment for the room, and the room was not equipped with self closing fire doors – Serious and $3500
- Inside flammable liquids storage room did not have a ventialtion system that would provide six air changes per hour – Serious and $3500
Explosives (Several lumped under 1910.109(b)(1)) – Serious and $4900
- no records of inspecting bonding and grounding stations
- room walls had unsealed openings for plumbing, conduit, and other utilities
- presses used in the making of fireworks not bonded and grounded
- trash inside process buildings
- employees in the process area were observed wearing cloths other than 100% cotton
- No emergency alarm system
- too many operators in the process area when explosion occurred
- No occupancy limits or weight restriction signs posted for the process areas
- Spark producing tools used in process areas
- Some exit doors did not have panic hardware
- Process building not posted with FIREWORKS – NO SMOKING signs
PSM
- No PSI on the ventilation system used on the explosives processing area – Serious and $4900
- PSI did not list the standards and codes employed for interlocks and safety shutdown systems – Serious and no dollar amount provided
- No documentation that the fireworks presses and ventilation system met a RAGAGEP – Serious and $4900
- PHA did not address fires, explosions, accidental ignition, chemical exposures, humidity, wind, lightning, ignition sources, and mixing incompatibles – Serious and $4900
- PHA did not address engineering and administrative controls – Serious and no dollar amount provided
- PHA did not address facility siting in regards to on-site traffic patterns and parking and introduction of ignition sources (mowers, weed eaters, snow plows, chainsaws) – Serious and no dollar amount provided
- PHA did not address human factors – Serious and no dollar amount provided
- PHA did not address the range of possible safety and health effects of failures of controls such as am/fm radios being used in HAZLOCs and workers not following procedures -Serious and no dollar amount provided
- PHA was not performed by a team with expertise in engineering and process operations and the team did not include at least one person knowledgeable/experienced in the process being analyzed (NOTE: Safety Director appears to have done the PHA alone) – Serious and no dollar amount provided
- Normal Operation SOP did not address the safety system (i.e. ventilation) in the process and storage areas – Serious and $4900
- SOPs did not include emergency shutdown and/or emergency operations procedures – Serious and $4900
- SOPs did not cover the mixing of composites for incendiary pellets – Serious and $4900
- No SOPs available for the incendiary pellet production in a press room – Serious $4900
- SOPs not reviewed and certified annually – Serious and $4900
- Not evaluating contractors who work on or near the PSM covered process – Serious and $4900
- No PSSR done on a new press room for producing incendiary pellets – Serious and $4900
- No MOCs on new or modified pieces of equipment ( a incendiary pellet press was modified and a window air conditioning unit was installed) – Serious and $4900
- No written Mechanical Integrity procedures- Serious and $4900
- Employees not trained in maintenance activities needed to keep a pellet press in safe working condition – Serious and $4900
- Equipment was operated outside of its established safe condition (e.g. deficiencies with a tablet press required employees to keep their left hand positioned on the upper left adjustment wheel) – Serious and $4900
- No investigation on a flash fire while buring trash behind a warehouse that caused a grass fire several weeks before the inspection – Serious and $4900
- Investigation was not started within 48 hours of the incident – Serious and no dollar amount provided
- NO 3-year PSM audits conducted – Serious and $4900
- No control over spare parts (dies used in tablet presses were not controlled to ensure they were compatible with the process) – Other-than-serious and $00.00
PPE
- Employees working with explosives were not required to wear 100% cotton (static protection) – Serious and $4900
- Employer provided dust masks that were not NIOSH approved (Note: the box of respirators stated “does not provide NIOSH approved respiratory protection”) – Other-than-serious and $00.00
- Employees with full beards were wearing 1/2 mask APRs – Other-than-serious and $00.00
LOTO
- No machine specific LOTO procedures on the tablet presses
Power Presses
- The tablet press did not have a disconnect switch – Serious and $3500
- The tablet press was not properly guarded – Serious and no dollar amount provided
- Operators of the tablet press were not trained before being allowed to operate it – Serious and $4900
Power Transmission
- The drive belts and pulleys on the tablet press were unguarded – Serious and $3500
Electrical
- A window air condition installed in a process building was not approved for Class II Div 2 areas (same one they got dinged on for the MOC issue) – Serious and $4900
Explosives
- Shipping containers used as Class I and II magazines were not labeled “Explosives – KEEP OFF” – Serious and $0.00
- Trucks used to move explosives on company property were not equipped to protect explosives from moisture or sparks -Serious and $0.00