Unsafe use of chlorine gas was discovered by OSHA in September 2014 after a complaint prompted an inspection. Investigators found employees endangered by permit-required confined space hazards while working in foundry furnaces. As a result, OSHA issued 31 serious health and safety citations with proposed penalties of $160,200. Inspectors determined the company failed to train workers on hazardous chemicals used at the foundry; store oxygen and fuel-gas cylinders properly, and protect workers from dangerous machine parts. The agency also found forklifts with defects in use. Company also failed to conduct audiometric testing; ensure hearing protection was worn; and to train employees on noise hazards. Here is a breakdown of the PSM related citations:
CAUTION: The material found in these posts is taken from OSHA citations BEFORE the “informal” takes places. This material is posted for AWARENESS purposes only. I have scrubbed company names and locations from my postings, but not from the OSHA documents. These are in NO WAY meant to shame any company, just providing information showing the things OSHA/EPA is finding in their PSM/RMP inspections.
Citation 1 Item 1
Type of Violation: Serious; $4,500
29 CFR 1910.119(c)(1): The employer did not develop a written plan of action regarding the implementation of the employee participation required by this paragraph:
At the facility a written plan of action regarding the employee participation had not been developed nor implemented to determine how employee(s) and/or their employee representatives will be consulted on the development of all process safety management elements.
Employee(s) were exposed to the release of chlorine compounds to the atmosphere that can lead to injury or death to persons working at the facility.
Citation 1 Item 2
Type of Violation: Serious; $5,400
29 CFR 1910.119(d): The employer failed to complete a compilation of written safety information to enable the employer and the employees involved in operating the chlorine process to identify and understand the hazards posed by the chlorine process. The employer failed to compile process safety information on the following technology and equipment used in the process:
Employee(s) working in the chlorine process did not have access to the following process safety information:
- metal tubing used to connect the ton cylinder to the process piping
- lead washers
- ton cylinders
- Jamesbury valves
- chlorine spreader bar used to lift ton cylinders
- chlorine hard metal piping
- evaporators
- isolation valves (yoke)
- chlorine storage racks
- pipe thread tape used in the chlorine process
- evaporator pressure relief valves
- inline rupture discs for the 2 evaporators
- chlorine flexible metal Piping
Citation 1 Item 3
Type of Violation: Serious; $4,500
29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices:
At the facility, the over-pressurization of the liquid or gas chlorine pipe lines and the outside chlorine gas sensors share the same alarm system. This does not comply with recognized and generally accepted good engineering practices. In the event of an over-pressurization of a liquid or gas pipe line, the activation of the alarm system would be the same as chlorine gas being detected by the chlorine gas sensors located in the evaporator room and outside at the chlorine cylinder connecting area.
Employees responding to an alarm would not be able to distinguish between different scenarios until they arrived at the chlorine processing area.
Citation 1 Item 4
Type of Violation: Serious; $6,300
29 CFR 1910.119(e)(1): The employer did not perform an initial process hazard analysis (hazard evaluation) on processes covered by 29 CFR 1910.119:(a):
The employer did not perform an initial process hazard analysis for the chlorine process.
Citation 1 Item 5
Type of Violation: Serious; $6,300
29 CFR 1910.119(f)(1): The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least’ the following elements:
- At the facility, the employer failed to provide to employees connecting chlorine cylinders to the process written operating procedures providing clear instructions addressing the following elements:
- temporary operations
- emergency operations
- start-up following an emergency shut down
- operating limits
- consequences of deviations
- steps required to correct deviations
- At the facility the employer did not develop written operating procedures that provided clear instructions to safely operate the evaporators, for all chlorine operators.
- At the facility the employer did not develop written operating procedures that provided clear instructions to safely change out chlorine tubes that are inserted into the molten metal at the furnaces.
Citation 1 Item 6
Type of Violation: Serious; $4,500
29 CFR 1910.119(g)(1)(i): Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee’s job tasks:
At the establishment the employer had not provided process safety management training to operators and maintenance personnel performing tasks in the chlorine process.
Citation 1 Item 7
Type of Violation: Serious; $3,600
29 CFR 1910.119(h)(2)(i): The employer, when selecting a contractor, did not obtain and evaluate information regarding the contract employer’s safety performance and program:
At the establishment the employer did not obtain the safety and health programs of the contractor that delivers chlorine ton cylinders and the contractor that maintains the integrity of the chlorine process.
Citation 1 Item 8
Type of Violation: Serious; $6,300
29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment:
- The employer did not develop and implement a written mechanical integrity procedure that addressed inspecting pressure vessels and piping for corrosion, minimum wall thickness, etc.
- The employer did not develop a written integrity procedures for evaluating the metallic flexible tubing that are changed out every 6 months to determine if the replacement policy was adequate.
- The employer did not develop and implement a written procedure for evaluating valves in the chlorine process.
- The employer did not develop and implement a procedure for evaluating ton cylinders received from a contractor for the chlorine process.
Citation 1 Item 9
Type of Violation: Serious; $6,300
29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment in accordance with paragraphs (ii) and (iii) of 191O.119(j)(4).
- At the facility the Chlorine piping along the north and east wall of the Chlorine process had not received non-destructive testing to determine if the manufacturer’s minimum wall thickness had been exceeded.
- At the facility the Chlorine piping from the evaporator room to the furnaces had not received nondestructive testing to determine if the manufacturer’s minimum wall thickness had been exceeded.
- At the facility the evaporators in the Chlorine process had not received mechanical integrity inspections for corrosion.
- At the facility pressure vessels such as the liquid expansion vessel had not received a mechanical integrity inspection to determine if there were any corrosion damage and to establish a corrosion rate for the vessel.
Citation 1 Item 10
Type of Violation: Serious; $2,700
29 CFR 1910.119(n): The employer did not establish an emergency plan for the entire plant in accordance with the provisions of 29 CFR 1910.38:
At the establishment a written emergency action plan did not address procedures to be followed by employee(s) required to remain at their position to plug any of the furnaces in the production department before they can evacuate, during a chlorine gas leak.
Citation 1 Item 11
Type of Violation: Serious; $6,300
29 CFR 1910.120(q)(1): The employer did not develop and implement an emergency response plan to handle anticipated emergencies prior to commencement of emergency response operations:
At the facility a written emergency response program had not been developed nor implemented to inform employees responding to Chlorine gas/liquid leaks in the Chlorine process of the health hazards associated with Chlorine.
Citation 1 Item 12
Type of Violation: Serious; $6,300
29 CFR 1910.147(c)(1): The employer did not establish a program consisting of an energy control procedure, employee training and periodic inspections to ensure that before any employee performed any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative:
At the establishment the employer had not developed and implemented a written energy control program designed to ensure employees were not exposed to the unexpected energization of the equipment when performing maintenance and preventative maintenance on the furnaces, rotaries, evaporators, and etc.
Citation 1 Item 13
Type of Violation: Serious; $4,500
29 CFR 1910.157(g)(1): An educational program was not provided for all employees to familiarize them with the general principles of fire extinguisher use and the hazards involved with incipient stage fire fighting:
Employee(s) utilizing fire extinguishers to address small incipient stage fires at the establishment were exposed to fire hazards due to no fire extinguisher training being performed.
CLICK HERE for the Citations