OSHA has cited a specialty chemical manufacturer for 20 safety violations following a plant explosion that resulted in the hospitalization of approximately 40 employees of other companies, working in the surrounding area, for decontamination. The May explosion was caused by a runaway reaction from an overheated reactor. During the production of a compound used in water treatment, an increase in temperature caused the reactor to overpressurize, rupturing the dome cover and blowing a hole in the roof of the facility. In response to the incident, OSHA conducted an inspection under the PSM NEP for covered chemical facilities. Proposed penalties total $77,000. Here is a break down of the citations:
Emergency
- 1910.37(a)(1) Exits were not kept free and unobstructed. (Serious; $3,500)
Propane (associated with PITs)
- 1910.110(e)(4)(iii) LP gas cylinder was not properly secured to the PIT. The latch was broken. (Serious; $3,500)
Process Safety Management
- PSI
- 1910.119(d)(3)(i)(B) P&ID’s did not include all piping, equipment, valves, and other components of process equipment (Serious; $4,900)
- 1910.119(d)(3)(i)(D) did not maintain relief valve calculations and design for 2 vessels and a condensation receiver (Serious; $4,900)
- PHA
- 1910.119(e)(1) no initial PHA (Serious; $4,900)
- 1910.119(e)(3)(iv) PHA did not address the loss of cooling water and had no provisions for back-up cooling water source. (Serious; $4,900)
- 1910.119(e)(3)(iv) PHA did not address and consider the facility siting of the control room which was located in the vicinity of six (6) reactors (Serious; $0)
- Operating Procedures
- 1910.119(f)(1) SOPs did not include and reflect all operating parameters, including emergency shutdown, PPE, consequences of deviation, and temporary operations. (Serious; $4,900)
- 1910.119(f)(4) No safe work practices for doing high risk maintenance task on covered process (Serious; $4,900) – NOTE: citation does not specify which safe work practices were not implemented.
- Training
- 1910.119(g)(1) Not all employees received initial training on the SOPs
- Mechanical Integrity
- 1910.119(j)(2) MI procedures not implemented (Serious; $4,900)
- 1910.119(j)(3) NO training for employees and contractors on MI procedures (Serious; $0)
- Management of Change
- 1910.119(l)(1) MOC program was not implemented (Serious; $4,900)
- 1910.119(l)(3) NO training on changes before start-up. (Serious; $0)
- Emergency Planning and Response
- 1910.119(n) The EAP/ERP did not include procedures for small releases (Serious; $4,900)
- 1910.120(q)(6)(ii) First responders at the Operations level did not receive at least 8 hours of training or did not have sufficient experience to objectively demonstrate competencies (Serious; $0)
- Permit-Required Confined Spaces
- 1910.146(c)(2) employees not informed of PRCS by posting or other effective means (Serious; $2,100)
- 1910.146(e)(1) entry permits were not issued prior to workers entering reactors, tanks and other spaces (Serious; $3,500)
- 1910.146(g)(1) training was not provided for all employees participating in CS entry activities (Serious; $0)
- Eyewash/Showers
- 1910.151(c) SS/EW were either not available, maintained, and/or accessible in areas where workers were exposed to caustic soda, maleic acid, etc. (Serious; $4,200)
- Fire Extinguishers
- 1910.157(c)(1) three fire extinguishers (Lobby, control room and process area) were not mounted, located and identified so that they were readily accessible (Serious; $3,500) NOTE: the FE in the control room was being used as a “door stop”!
- 1910.157(e)(3) fire extinguisher in the control room upper mezzanine did not receive an annual inspection (Serious; $0)
- 1910.157(g)(3) employees expected to utilize fire control devices were not provided “appropriate” hands-on training (Serious; $0) NOTE: not sure if the employees received some type of hands on training and the CSHO just subjectively though it was not appropriate or the use of the word “appropriate” is just applied incorrectly in the citation wording. The employer shall provide employees who have been designated to use fire fighting equipment as part of an emergency action plan with training in the use of the appropriate equipment.
- 1910.165(b)(1) employer did not sound the evacuation alarm on the day of the explosion (Serious; $3,500)
- Forklifts/PITs
- 1910.178(l)(1)(i) not all employees operating PITs were trained (Serious; $3,500)
- Welding, Cutting, Brazing (Compressed Gas Cylinders)
- 1910.253(b)(2)(iv) two argon cylinders stored in the maintenance shop were missing their safety cap (Serious; $3,500)
- 1910.253(b)(2)(iv) three oxygen and two acetylene cylinders stored together in the shipping/receiving area (Serious; $0)
- Electrical
- 1910.305(b)(2) a 120/240 electrical cabinet in the boiler house did not have a cover (Serious; $2,800)
- 1910.303(f)(2) electrical breakers in a cabinet in the boiler house were not labeled (Serious; $0)
- HAZCOM
- 1910.1200(f)(5)(i) two (2) 10,000 gallon tanks of hydrogen peroxide and maleic acid were not labeled (Serious; $3,500)
- 1910.1200(g)(1) three (3) boiler room chemicals did not have an MSDS (Serious; Corrected during inspection)
- 1910.1200(h)(1) not all employees received HAZCOM training (Serious; $0)
- 1910.1200(g)(2)(i)(C)(3) two (2) MSDS’s did not list all of the ingredients (Serious; $700)
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