OSHA has cited a manufacturer of polystyrene foam core board for willful, repeat and serious safety violations. The business faces a total of $105,490 in proposed penalties following two inspections by OSHA’s Hartford Area Office. The first inspection, begun on May 31, identified several deficiencies in the plant’s process safety management program involving the chemical isopentane, a flammable liquid used in the manufacturing process. OSHA found that the company did not inspect or test process equipment, including the isopentane tank, piping and pressure relief valves. This resulted in the issuance of one willful citation, with a $53,900 fine. One repeat citation, with a fine of $10,780, was issued for a lack of written procedures to maintain the ongoing integrity of process equipment. A similar hazard was cited in 2009. Six serious citations, with $26,180 in fines, were issued for incomplete process safety information, hazard analyses and documentation, and for lack of readily available fire extinguishers and fire extinguisher training. Here is a breakdown of the citations:
Citation 1 Item 1a
Type of Violation: Serious; $5,390
29 CFR 1910.119(d)(3)(i)(B): The employer’s piping and instrument diagrams did not include information that provided specific identification of equipment that is part of the process.
The employer’s piping and instrumentation diagrams did not include information, such as, but not limited to: The set pressure for the pressure relief valves installed on the 18,000-gallon isopentane vessel or the pressure relief valves at the Corken pumps, the maximum allowable working pressure on the isopentane vessel, and documentation of the pressure relief stacks provided.
Citation 1 Item 1b
Type of Violation: Serious; Grouped
29 CFR 1910.1l9(d)(3)(i)(D): The employer did not include, in the process safety information compilation, the relief system design and the design basis.
The process safety information maintained by the employer did not include information on the relief system design basis for the two Fisher H282-250 Series Large Internal Spring Relief Valves installed on the isopentane vessel and the two Corken Bl66 pressure relief valves.
Citation 1 Item 1c
Type of Violation: Serious; Grouped
29 CFR 1910.119( d)(3)(i)(F): Design codes and standards pertaining to the equipment in the process were not compiled before conducting any process safety analysis required by this standard.
The employer had not documented the design codes employed in designing the pressure relief system for the process using isopentane as a blowing agent.
Citation 1 Item 2
Type of Violation: Serious; $3,850
29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices.
The employer did not comply with a RAGAGEP, such as, but not limited to ASME Boiler and Pressure Vessel Code, Section VIII or API 520, in that:
- The employer did not document the inlet pressure drop for pressure relief valves used to protect the pressure vessel containing isopentane.
- The employer did not document the built up back pressure of the pressure relief valves used to protect the pressure vessel containing isopentane.
Citation 1 Item 3a
Type of Violation: Serious; $5,390
29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not consider consequences of failure of engineering and administrative controls.
The process hazard analysis provided by the employer did not take into consideration the consequences of failure of engineering and administrative controls, such as, but not limited to, failure of Drager gas detection system.
Citation 1 Item 3b
Type of Violation: Serious; Grouped
29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting.
The employer did not consider the effects an overpressure and rupture of the pressure vessel of isopentane would have on the occupied structures on the site.
Citation 1 Item 3c
Type of Violation: Serious; Grouped
29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not address human factors.
The company’s process hazard analysis did not consider the following:
- Shift changes and the circumstances that could effect processes, such as the maintenance of covered equipment.
- Employee fatigue, as the employer operates the covered process on a 3-shift schedule.
Citation 1 Item 4
Type of Violation: Serious; $3,850
29 CFR 1910.119(f)(3): The employer did not annually certify that operating procedures were current and accurate.
The employer had not reviewed. written operating procedures annually, including, but not limited to the following:
- The operating procedure for receiving isopentane, File #PP-740, was dated October 20, 2005 and had not been reviewed annually.
- The company’s Emergency Action Plan, File #PP-887-02, was dated January 19, 2011 and had not been reviewed within the past year. The Emergency Action Plan included emergency shut down procedures for process equipment.
Citation 1 Item 5
Type of Violation: Serious; $3,850
29 CFR 1910.157(c)(l): Portable fire extinguishers were not mounted, located and identified so that they were readily accessible without subjecting the employees to injuries.
Portable fire extinguishers at locations L1, L2, L3 were not mounted. They were located on the floor and were subject to tipping over. There was no portable fire extinguisher present in position L4.
Citation 1 Item 6
Type of Violation: Serious; $3,850
29 CFR 1910.157(g)(2): The educational program to familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage fire fighting was not provided to all employees upon initial employment, and at least annually thereafter.
All employees who were authorized to remain on site after an emergency evacuation to fight incipient stage fires had not been trained annually on proper portable fire extinguisher usage.
Citation 2 Item 1
Type of Violation: Willful; $53,900
29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment.
The employer had not performed inspections and tests on process equipment, including, but not limited to:
- Pressure vessels;
- piping systems;
- valves;
- relief and vent systems and devices;
- emergency shutdown systems;
- monitoring devices and sensors;
- alarms;
- interlocks; and
- pumps used in the process where isopentane was used as a blowing agent.
Citation 3 Item 1
Type of Violation: Repeat; $10,780
29 CFR 191O.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment.
The employer had not developed and implemented specific written procedures to address regular inspections and preventive maintenance to covered processes in accordance with recognized and generally accepted good engineering practices. The procedures would need to cover tanks, pumps, piping and process equipment used for the foam board production line that used isopentane as a blowing agent.
The business was previously cited for a violation of this standard or its equivalent standard (191O.119(j)(2)), which was contained in OSHA inspection number 3117 59021, Citation Number 1, Item Number 1Oa and was affirmed as a final order on March 16, 2009.
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