Following the death of an employee, 61, OSHA has cited the chemical manufacturer for 21 serious and two other-than-serious safety violations. Many of the violations involve OSHA’s Process Safety Management Standards. The company has been placed in OSHA’s Severe Violator Enforcement Program. OSHA’s investigation found the employee suffered fatal injuries on April 4, 2014, while clearing a blockage on the drain line to a reactor. An expansion joint failed and caused a thermally heated chemical mixture to spew onto the employee. The mixture predominately contained Bisphenol A, commonly known as BPA, and hydrochloric acid, acetone and phenol, used in the manufacture of resins, flame retardants and coatings. The inspection found plant officials failed to ensure misaligned pipes and expansion joints were repaired properly and adequate safety shields were installed before placing the reactor back in service. The company also failed to develop procedures for normal and emergency shutdown of the BPA reactor; address hazards for expansion joint failure; develop written procedures to maintain equipment used to process chemicals during maintenance; and train workers to install flexible expansion joints and associated equipment properly. In addition, the company failed to conduct required inspections and maintain accurate inspection records; provide personal protective equipment, including clothing, boots, safety goggles and head coverings; and train workers to identify and handle hazardous chemicals. OSHA has proposed fines of $134,000. Here is the breakdown of the PSM citations:
PLEASE NOTE: these citations are NOT the final settlement and some are BEFORE the employer’s informal conference. They are shared as a learning tool to show what types of issues OSHA and EPA are finding in their PSM/RMP inspections. I have scrubbed all company information from these postings as this is NOT about any one company, but rather a trend of issues that continue to be found by OSHA and EPA.
Citation 1 Item 1
Type of Violation: Serious; $7,000
29 CFR 1910.119(d)(3)(i)(F): Information pertaining to the equipment in the process did not include design codes and standards that were employed.
(a) The 2011 Process Hazard Analysis (PHA) did not include process safety information related to the temperature, pressure and directional flow limitations of Teflon expansion joints made by Ethylene that were used in the reactor dump lines.
Citation 1 Item 2a
Type of Violation: Serious; $7,000
29 CFR 1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process.
(a) The employer’s 2011 Process Hazard Analysis (PHA) did not address or evaluate the hazards present due to contact with hot process chemicals, such as phenol, BPA, acetone and hydrochloric acid at approximately 130 degrees F, in the event of failure of the expansion joint, such as the Ethylene expansion joint located below Stage 1 Reactor R-109 to the dump line to Outlet Reaction Buffer Drum Tank D-101 or other expansion joints used in the facility.
Citation 1 Item 2b
Type of Violation: Serious; Grouped
29 CFR 1910.119(e)(3)(ii): The process hazard analysis did not address the identification of any previous incident which has a likely potential for catastrophic consequences in the workplace:
(a) The 2011 Process Hazard Analysis (PHA) did not address the identification of six previous incidents with expansion joint failures in BPA that occurred between 2008 and 2010 as having potential for catastrophic consequences despite previous PHAs identifying this equipment as having incidents requiring action and the number of failures that included one where an expansion joint blew out while steaming equipment that occurred on December 4, 2010. The PHA review group still did not consider the incidents to have the potential for a catastrophic event. Since that time there have been six additional leaks or blow-outs of these joints leading up to April 4, 2014, when an expansion joint blowout while steaming equipment caused a catastrophic consequence. Further there have been an additional 21 instances of replacement of expansion joints per maintenance work orders since 2011.
Citation 1 Item 2c
Type of Violation: Serious; Grouped
29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not address human factors.
(a) The 2011 process hazard analysis did not address human factors associated with steaming the dump line from Stage 1 Reactor R-109 to Outlet Reaction Buffer Drum Tank D-101, for clearing plugged lines with steam in that a human factor evaluation would have noted that the sight glass was located approximately three feet below the operator’s eye level, or 33 inches above the catwalk floor, and therefore the position of the equipment impacted the ability to rapidly escape from a leak of hot process chemicals, such as phenol, BPA, acetone and hydrochloric acid.
Citation 1 Item 3
Type of Violation: Serious; $7,000
29 CFR 1910.119(f)(1)(iii)(E): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and did not address any special or unique hazards:
(a) The employer’s reactor shutdown procedure for BPA Reactors (SJP R-101-b) which was revised on 7/23/2002, did not address the hazards of expansion joint failure due to steaming of the reactor dump line when Step 5(a) ofthat procedure requires steaming the dump line from the reactors (e.g., R-109) to Drum D-1 01 prior to draining the reactor and Step 5( c) of that procedure requires steaming the same dump line to clear it after draining.
Citation 1 Item 4
Type of Violation: Serious; $5,000
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:
(a) The employer did not have copies of the Sunoco Contractors Pre-qualification Package for the maintenance contractor, CB&I Stone and Webster Construction, Inc., that had been retained after the facility was purchased from Sunoco on November 1, 2011, and had not evaluated the safety performance and program of the contractor themselves.
(b) The pipe inspection contractor, Mistras Group, Inc., safety performance and program was not evaluated by Haverhill prior to the award of their contract.
Citation 1 Item 5
Type of Violation: Serious; $5,000
29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment.
(a) The employer did not establish and implement written procedures for maintaining the mechanical integrity of the process for Haverhill in-house maintenance employees and contracted maintenance employees to follow for performing routine job tasks that were not classified as preventive or predictive maintenance, such as but not limited to replacement ofTeflon expansion joints made by Ethylene that failed and fabrication of pipe spools of Teflon lined pipe that were out of alignment.
(b) The employer did not implement written procedures for maintaining the mechanical integrity of the process as found in API Recommended Practice 574 and the employer’s Mechanical Integrity Program for inspection of expansion joints (HAV-MI-PR0-0507) in that:
- Expansion joints were not regularly inspected;
- Expansion joints that were insulated did not have all of the insulation removed for inspection and were not inspected unless visible leaks were detected through the insulation;
- Expansion joint safety shields were not used for personnel protection.
(c) The employer did not establish and implement written procedures for maintaining the mechanical integrity ofTeflon lined piping in the Phenol and BPA units, as they did not perform non-destructive testing on lined piping, and did not follow the manufacturer’s recommendations for flange bolt torquing, retorquing, hydrotesting, annual retorquing and pressure testing of Restoflex PTFE Lined Piping Products.
(d) The employer’s vibration analysis program HAV-MI-PR0-0509 did not contain written procedures for performance of vibration analysis on rotating equipment in the Phenol processing unit and the logistics unit.
(e) The employer’s HAV-PSM-PR0-008, Predictive/Preventive Maintenance Procedure PPM #10ldid not contain written procedures for performing daily inspections of pumps in areas of the facility such as the logistics unit and the phenol processing unit.
(f) The employer did not establish and implement written procedures for performing internal inspections on pumps located in the Phenol processing unit and the logistics unit (HAV-PSM-PR0-008, Predictive/Preventive Maintenance Procedure PPM #101).
(g) The employer did not establish and implement written procedures for conducting external pumps inspections in the Phenol processing unit and the logistics unit.
(h) The employer did not establish and implement written procedures for increasing or decreasing inspection intervals of process equipment, such as but not limited to piping, pressure vessels, pumps, and pressure relief valves.
(i) Procedures that provide clear instructions for safely conducting activities associated with draining the Primary Reactors including Reactor R-109, in that the existing procedures (SJP G-26-a, SJP R-101-b) did not address the special hazards of leaking expansion joints in the reactor dump lines and the need for safety shields surrounding the expansion joints in the event they did leak or fail and the corresponding precautions necessary to prevent employee exposure to hot process chemicals, such as phenol, BPA, acetone and hydrochloric acid.
(j) The employer did not establish and implement written procedures for the installation and maintenance of expansion joint covers used for personnel protection.
(k) The employer did not establish and implement written procedures for contractors who were hired to patch the glass linings of reactor vessels.
Citation 1 Item 6
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(3): The employer did not train each employee involved in maintaining the ongoing integrity of process equipment in the procedures applicable to the employee’s job tasks to ensure that the employee can perform the job tasks in a safe manner:
(a) Haverhill in-house maintenance employees and contracted maintenance employees were not provided with the training necessary to perform their job duties effectively and were not provided with written procedures for maintaining the ongoing integrity of the process that were not classified as preventive or predictive maintenance, such as but not limited to replacement of Teflon expansion joints made by Ethylene that failed and fabrication of pipe spools of Teflon lined pipe that were out of alignment.
Citation 1 Item 7
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment.
(a) The employer did not inspect Ethylene expansion joints in accordance withAPI Recommended Practice 57 4 and the employer’s Mechanical Integrity Program for inspection of expansion joints (HAVMI-PR0-0507).
(b) The employer did not follow the manufacturer’s recommendations for flange bolt torquing, retorquing, hydrotesting, annual retorquing and pressure testing of Resto flex Plastic Lined Piping Products which were used in the BPA and Phenol units.
(c) The employer did not perform vibration analysis on rotating equipment in the Phenol processing unit and the logistics unit (HAV-MI-PR0-0509).
(d) The employer did not perform daily inspections of pumps in areas of the facility such as the logistics unit and the phenol processing unit (HAV-PSM-PR0-008, Predictive/Preventive Maintenance Procedure PPM #101).
(e) The employer did not perform internal inspections on pumps located in the Phenol processing unit and the logistics unit (HAV-PSM-PR0-008, Predictive/Preventive Maintenance Procedure PPM #101).
(f) The employer did not conduct external pumps inspections in the Phenol processing unit and the logistics unit.
(g) The employer did not increase or decrease inspection intervals of process equipment, such as but not limited to piping, pressure vessels, pumps, and pressure relief valves in accordance with API recommendations.
(h) Visual external piping checklists did not include inspecting welds on large diameter piping.
Citation 1 Item 8
Type of Violation: Serious; $7,000
29 CFR 191O.119(j)(4)(ii): Inspections and testing procedures performed on process equipment to maintain its mechanical integrity did not follow recognized and generally accepted good engineering practices (RAGAGEP):
(a) The employer did not inspect or test Resistoflex PTFE lined piping used in the facility unless it was obviously leaking or clogged.
(b) Intervals on valves were not inspected per API 570.
Citation 1 Item 9
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment was not consistent with applicable manufacturers’ recommendations and good engineering practices (REGAGAP), and more frequently if determined to be necessary by prior operating experience.
(a) The employer did not ensure annual visual inspections of the Safety Instrumented Systems for phenol 2 and 3 were performed on a periodic basis according to ANSI/ISA 84 section 16.3.2 which states that SIS systems must periodically visually inspected to ensure there are no unauthorized modifications and observable deterioration to system components. (HAV-PH2-PR0-025)
(b) The employer did not ensure the inspection frequencies for pumps located in the phenol processing area and the logistics department were based on CCPS Guidelines for Mechanical Integrity Systems 2006 ed. which states on page 172 that pumps are required to have vibration analysis performed weekly to quarterly, rotational checks performed weekly to monthly, analysis of gear box and bearing lubricant performed monthly to semi-annually.
(c) The employer did not conduct internal inspections of vessel 3301-E, a crude acetone column located in the Phenol 2 unit that is approximately 200 feet tall, with 97 thickness management locations (TML) for testing on the vessel and 32 of the testing points were past due for inspection every 10 years according to API 510. (Haverhill document HAV-MI-PR0-0591 states that ultrasonic inspections shall be made either internal or external.)
(d) The employer did not conduct internal inspections of vessel 3307-E, a phenol finishing column located in the Phenol 2 unit, that is approximately 62 feet tall and is lined with stainless steel cladding, with 71 TML testing locations on the vessel and 34 of the testing points were past due for inspection every 10 years according to API 510.
(e) The employer did not conduct internal inspections of vessel 3307-E, a hydrocarbon removal column located in the Phenol 2 unit, that is approximately 134 feet tall and is lined with stainless steel cladding, with 127 TML testing locations on the vessel and 17 of the testing points were past due for inspection every 10 years according to API 510.
(f) The employer did not conduct internal inspections of vessel 3301-D, a phenol resin bed located in the Phenol 2 unit and is approximately 18 feet tall, unclad, with 21 TML testing locations on the vessel and 1 of the testing points on the shell was past due for inspection every 10 years according to API 510.
(g) The employer did not ensure that approximately 1000 piping inspections, for piping segments and inspection points containing the Class I flammable chemicals acetone, cumene hydrogen peroxide and cumene, were conducted at intervals according to API 570 and Haverhill Mechanical Integrity piping procedures.
Citation 1 Item 10
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(4)(iv): The employer did not document each inspection and test that was performed on process equipment. The documentation shall ·identify the date of the inspection, the name of the person who performed the inspection, the identifier of the equipment inspected, a description of the inspection and the result of the inspection.
(a) On or about April 3, 2014 no inspection records were kept of required inspections, such as visual inspections and pressure testing, of the newly installed Teflon expansion joint made by Ethylene as described in HAV-MI-PR0-0507 Mechanical Integrity Guide-Expansion Joints.
Citation 1 Item 11
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(5): The employer shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation:
(a) On or about April 3, 2014, before the four inch Teflon expansion joint made by Ethylene was replaced at the bottom of Stage 1 Reactor R-109 to the dump line to Outlet Reaction Buffer Drum Tank D-101, the misaligned pipes were not repaired prior to placing the reactor back in service, to prevent employee exposure to 130 degree F process chemicals, such as phenol, BPA and HCl, in case of expansion joint blow out.
Citation 1 Item 12
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(6)(ii): Appropriate checks and inspections were not performed to assure that equipment was installed properly and consistent with design specifications and the manufacturer’s instructions.
(a) On or before April 3, 2014 the employer did not perform appropriate checks and inspections, such as but not limited to ensure the Teflon expansion joint made by Ethylene below Stage 1 Reactor R-109 to the dump line to Outlet Reaction Buffer Drum Tank D-101 was installed properly and consistent with manufacturer specifications, in that the Ethylene expansion joint was installed without a liner sleeve, with cut limit links, with lateral misalignment of the piping and was not fitted with an adequate safety shield.
Citation 1 Item 13
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(6)(iii): The employer shall assure that maintenance materials, spare parts and equipment are suitable for the process application for which they will be used.
(a) On or about April 3, 2014 the Teflon expansion joint made by Ethylene installed at the discharge dump line from bottom of Stage 1 Reactor R-109 to the dump line to Outlet Reaction Buffer Drum Tank D-101 was not suitable for the piping where it was used because:
- The expansion joint was dimensionally too short.
- The expansion joint was installed into a piping system where thermal pipe growth from steaming resulted in lateral deflection forces on the expansion joint that resulted in its misalignment beyond the manufacturers limits for lateral misalignment of 0.67 inches.
- The dump line piping system was not fitted a device or a work practice (condensate bleed) to ameliorate pressure liquid momentum surges (e.g. water hammer).
- The failed R-109 expansion joint would experience temperatures and pressures exceeding the manufacturers recommended limits if subject to available steaming pressures of 75 psig and 150 psig.
Citation 1 Item 14a
Type of Violation: Serious; $7,000
29 CFR 1910.132(a): Protective equipment was not used when necessary whenever hazards capable of causing injury and impairment were encountered:
(a) On or about April 4, 2014, an employee was not wearing personal protective equipment, such as safety goggles, rubber boots, chemical resistant rain suit with the hood over his hard hat and chemical resistant pants (Haverhill PPE Required Per Job Task Matrix) when an expansion joint failed and the employee was exposed to approximately 130 degree process chemicals, such as phenol, BPA, hydrochloric acid and acetone.
Citation 1 Item 14b
Type of Violation: Serious; Grouped
29 CFR 1910.132(d)(1)(i): The employer did not assess the workplace to determine if hazards were present, or likely to be present, and did not select and have each affected employee use the types of Personal Protective Equipment (PPE) that would protect the affected employee from the hazards identified in the workplace hazard assessment:
(a) The employer did not address PPE to be used when employees were exposed to the hazards of working with Teflon expansion joints made by Ethylene in the BPA Reaction Building, such as but not limited to a face shield, safety goggles, rubber boots, long chemical resistant coat with the hood up over the hard hat and chemical resistant pants (Haverhill PPE Required Per Job Task Matrix) when employees were exposed to the possibility of expansion joint failure resulting in the release of 130 degree F mixture of chemicals under pressure which contained phenol, BPA, acetone and hydrochloric acid.
Citation 2 Item 1
Type of Violation: Other-than-Serious; $1,000
29 CFR 1910.119(h)(2)(vi): The employer did not maintain copies of OSHA 300 logs for contractors nested in the facility to perform maintenance and repairs,
(a) The employer did not have copies of the OSHA 300 Logs for the maintenance contractor, CB&I Stone and Webster Construction, Inc. (b) The employer did not have copies of the OSHA 300 Logs for the pipe inspection contractor, Mistras Group, Inc.
Citation 1 Item 1a
Type of Violation: Serious; $5,000
29 CFR 1910.37(a)(2): Exit routes must be arranged so that employees will not have to travel toward a high hazard area, unless the path of travel is effectively shielded from the high hazard area by suitable partitions or other physical barriers.
Along the West wall of the BPA facility, the employer did not ensure that the steam discharge from the 160 psi pressure safety valve was effectively shielded for employees who would have to use the emergency egress platform.
Citation 1 Item 1b
Type of Violation: Serious; Grouped
29 CFR 1910.3 7(a)(3): Exit routes must be free and unobstructed. No materials or equipment may be placed, either permanently or temporarily, within the exit route. The exit access must not go through a room that can be locked, such as a bathroom, to reach an exit or exit discharge, nor may it lead into a dead-end corridor. Stairs or a ramp must be provided where the exit route is not substantially level. ‘
In the BPA Area, R-1 09 and R- 110 walkways, the entire work platform leading to the exit was obstructed by permanently installed scaffold access ladders and valves, protruding into the platform and providing only 15 1/2 inches of platform aisleway on the way to the exit.
Citation 1 Item 2
Type of Violation: Serious ; $5,000
29 CFR 191 0.119(d)(3 )(ii): The employer shall document that equipment complies with recognized and generally accepted good engineering practices.
On or about May 1, 2014, the employer did not ensure Safety Instrumented System (SIS) bypass switches for phenol 2 and phenol 3 processes were protected by passcodes or key locks.
Citation 1 Item 3
Type of Violation: Serious; $7,000
29 CFR 1910.119(e)(5): The employer shall establish a system to promptly address the team’s findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.
The employer had not completed Finding #13308, from the 2011 PSG HES Compliance Audit to address the pressurization and alarm system in the BPA MCC and Distributed Control Room in a timely manner to address the toxic gas hazard from an uncontrolled release and dispersion identified in a Baker Risk Facility Siting Study completed in 2010.
Citation 1 Item 4a
Type of Violation: Serious; $5,000
29 CFR 1910.119(f)(1)(iii)(A): Properties of, and hazards presented by, the chemicals used in the process;
In the Phenol 2 Unit;
a. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure S-3512-J/JA-a (3512-J/JA Hydrogenation Feed Pump Start-up, Rev 10/27/2003) does not list Cumene concentrations can be explosive, material may accumulate a static charge, ingestion hazard, and overexposure may cause CNS depression as detailed in the MSDS.
b. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure S-3227-L-b (3227-L Primary Cumene Stripper Jets and Condensers Shutdown, Rev 5/7/20 12) does not list Cumene concentrations can be explosive, material may accumulate a static charge, ingestion hazard, and overexposure may cause CNS depression as detailed in the MSDS.
c. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure S-3206-L-a (Switching and Cleaning Acid Filter 3206-L, Rev 6/2911997) does not list Cumene concentrations can be explosive, material may accumulate a static charge, ingestion hazard, and overexposure may cause CNS depression as detailed in the MSDS.
d. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure F-3342-F-b (3342-F Shutdown, Rev 8/24/2006) does not list Cumene concentrations can be explosive, material may accumulate a static charge, ingestion hazard, and overexposure may cause CNS depression as detailed in the MSDS.
e. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure ISO A-3507-FA/FB-d (Recycle 3507-FA/FB to 3505-F, Rev 1/09/1998) does not list Cumene concentrations can be explosive, material may accumulate a static charge, ingestion hazard, and overexposure may cause CNS depression as detailed in the MSDS.
f. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure S-CHP Spills-a (CHP Spills Cleanup using soda ash, Rev 5/07/2012) does not list Cumene concentrations can be explosive, material may accumulate a static charge, ingestion hazard, and overexposure may cause CNS depression as detailed in the MSDS.
g. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure G-318-c (Electrical breaker and overload reset, Rev 9/1311999) does not list Cumene concentrations can be explosive, material may accumulate a static charge, ingestion hazard, and overexposure may cause CNS depression as detailed in the MSDS.
h. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure 314FA (314 FA Transfer into 3507FA/FB, No Rev date) does not list Cumene concentrations can be explosive, material may accumulate a static charge, ingestion hazard, and overexposure may cause CNS depression as detailed in the MSDS.
i. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure 3203-E (3203-E Pressure Testing, Rev 5/06/1997) does not list Cumene concentrations can be explosive, material may accumulate a static charge, ingestion hazard, and overexposure may cause CNS depression as detailed in the MSDS.
j. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure S-3512-J/JA-a (3512-J/JA Hydrogenation Feed Pump Start-up, Rev 10/27/2003) does not list Sulfuric Acid hazards such as potentially being fatal if swallowed as detailed in the MSDS.
k. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure S-3227-L-b (3227-L Primary Cumene Stripper Jets and Condensers Shutdown, Rev 5/7/20 12) does not list Sulfuric Acid hazards such as potentially being fatal if swallowed as detailed in the MSDS.
l. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure S-3206-L-a (Switching and Cleaning Acid Filter 3206-L, Rev 6/29/1997) does not list Sulfuric Acid hazards such as potentially being fatal if swallowed as detailed in the MSDS.
m. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure F-3342-F-b (3342-F Shutdown, Rev 8/24/2006) does not list Sulfuric Acid hazards such as potentially being fatal if swallowed as detailed in the MSDS.
n. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure ISO A-3507-FA/FB-d (Recycle 3507-FA/FB to 3505-F, Rev 1109/1998) does not list Sulfuric Acid hazards such as potentially being fatal if swallowed as detailed in the MSDS.
o. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure S-CHP Spills-a (CHP Spills Cleanup using soda ash, Rev 5/07/20 12) does not list Sulfuric Acid hazards such as potentially being fatal if swallowed as detailed in the MSDS.
p. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure G-318-c (Electrical breaker and overload reset, Rev 9113/1999) does not list Sulfuric Acid hazards such as potentially being fatal if swallowed as detailed in the MSDS.
q. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure 314FA (314 FA Transfer into 3507FA/FB, No Rev date) does not list Sulfuric Acid hazards such as potentially being fatal if swallowed as detailed in the MSDS.
r. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure 3203-E (3203-E Pressure Testing, Rev 5/0611997) does not list Sulfuric Acid hazards such as potentially being fatal if swallowed as detailed in the MSDS.
s. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure S-3512-J/JA-a (3512-J/JAHydrogenation Feed Pump Start-up, Rev 10/27/2003) does not list Cumene Hydroperoxide (CHP) hazards such as forming explosive mixtures in air, pulmonary aspiration hazard, central nervous system effects including drowsiness, dizziness, coma, and even death as detailed in the MSDS.
t. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure S-3227-L-b (3227-L Primary Cumene Stripper Jets and Condensers Shutdown, Rev 517120 12) does not list Cumene Hydroperoxide (CHP) hazards such as forming explosive mixtures in air, pulmonary aspiration hazard, central nervous system effects including drowsiness, dizziness, coma, and even death as detailed in the MSDS.
u. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure S-3206-L-a (Switching and Cleaning Acid Filter 3206-L, Rev 6/29/1997) does not list Cumene Hydroperoxide (CHP) hazards such as forming explosive mixtures in air, pulmonary aspiration hazard, central nervous system effects including drowsiness, dizziness, coma, and even death as detailed in the MSDS.
v. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure F-3342-F-b (3342-F Shutdown, Rev 8/24/2006) does not list Cumene Hydroperoxide (CHP) hazards such as forming explosive mixtures in air, pulmonary aspiration hazard, central nervous system effects including drowsiness, dizziness, coma, and even death as detailed in the MSDS.
x. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure ISO A-3507-FA/FB-d (Recycle 3507-FA/FB to 3505-F, Rev 1/09/1998) does not list Cumene Hydroperoxide (CHP) hazards such as forming explosive mixtures in air, pulmonary aspiration hazard, central nervous system effects including drowsiness, dizziness, coma, and even death as detailed in the MSDS.
y. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure S-CHP Spills-a (CHP Spills Cleanup using soda ash, Rev 5/07/2012) does not list Cumene Hydroperoxide (CHP) hazards such as forming explosive mixtures in air, pulmonary aspiration hazard, central nervous system effects including drowsiness, dizziness, coma, and even death as detailed in the
MSDS.
z. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure G-318-c (Electrical breaker and overload reset, Rev 9/13/1999) does not list Cumene Hydroperoxide (CHP) hazards such as forming explosive mixtures in air, pulmonary aspiration hazard, central nervous system effects including drowsiness, dizziness, coma, and even death as detailed in the
MSDS.
aa. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure 314 FA (314 FA Transfer into 3 507F AIFB, No Rev date) does not list Cumene Hydroperoxide (CHP) hazards such as forming explosive mixtures in air, pulmonary aspiration hazard, central nervous system effects including drowsiness, dizziness, coma, and even death as detailed in the
MSDS.
bb. The employer failed to develop and implement written operating procedures that provided clear instructions including the properties and hazards presented by chemicals used in the process. Procedure 3203-E (3203-E Pressure Testing, Rev 5/06/1997) does not list Cumene Hydroperoxide (CHP) hazards such as forming explosive mixtures in air, pulmonary aspiration hazard, central nervous system effects including drowsiness, dizziness, coma, and even death as detailed in the MSDS.
Citation 1 Item 4b
Type of Violation: Serious; Grouped
29 CFR 1910.119(f)(1)(iii)( C): Control measures to be taken if physical contact or airborne exposure occurs;
In the Phenol 2 Unit;
a. The employer failed to develop and implement written operating procedures that provided clear instructions inc! uding control measures to be taken if physical contact or airborne exposure occurs. Procedure S-3512-J/JA-a (3512-J/JA Hydrogenation Feed Pump Start-up, Rev 10/27/2003) does not list control measures to be taken if physical contact or airborne exposure occurs to Cumene such as seeking immediate medical attention should exposure to the eyes, ingestion, or inhalation occur as detailed in the MSDS.
b. The employer failed to develop and implement written operating procedures that provided clear instructions including control measures to be taken if physical contact or airborne exposure occurs. Procedure S-3227-L-b (3227-L Primary Cumene Stripper Jets and Condensers Shutdown, Rev 5/7/20 12) does not list control measures to be taken if physical contact or airborne exposure occurs to Cumene such as seeking immediate medical attention should exposure to the eyes, ingestion, or
inhalation occur as detailed in the MSDS.
c. The employer failed to develop and implement written operating procedures that provided clear instructions including control measures to be taken if physical contact or airborne exposure occurs. Procedure S-3206-L-a (Switching and Cleaning Acid Filter 3206-L, Rev 6/29/1997) does not list control measures to be taken if physical contact or airborne exposure occurs to Cumene such as seeking immediate medical attention should exposure to the eyes, ingestion, or inhalation occur as detailed in the MSDS.
d. The employer failed to develop and implement written operating procedures that provided clear instructions including control measures to be taken if physical contact or airborne exposure occurs. Procedure F-3342-F-b (3342-F Shutdown, Rev 8/24/2006) does not list control measures to be taken if physical contact or airborne exposure occurs to Cumene such as seeking immediate medical attention should exposure to the eyes, ingestion, or inhalation occur as detailed in the MSDS.
e. The employer failed to develop and implement written operating procedures that provided clear instructions including control measures to be taken if physical contact or airborne exposure occurs. Procedure ISO A-3507-FA/FB-d (Recycle 3507-FA/FB to 3505-F, Rev 1/0911998) does not list control measures to be taken if physical contact or airborne exposure occurs to Cumene such as seeking immediate medical attention should exposure to the eyes, ingestion, or inhalation occur as detailed in the MSDS.
f. The employer failed to develop and implement written operating procedures that provided clear instructions including control measures to be taken if physical contact or airborne exposure occurs. Procedure S-CHP Spills-a (CHP Spills Cleanup using soda ash, Rev 5/07/20 12) does not list control measures to be taken if physical contact or airborne exposure occurs to Cumene such as seeking immediate medical attention should exposure to the eyes, ingestion, or inhalation occur as detailed in the MSDS.
g. The employer failed to develop and implement written operating procedures that provided clear instructions including control measures to be taken if physical contact or airborne exposure occurs. Procedure G-318-c (Electrical breaker and overload reset, Rev 911311999) does not list control measures to be taken if physical contact or airborne exposure occurs to Cumene such as seeking immediate medical attention should exposure to the eyes, ingestion, or inhalation occur as detailed in the MSDS.
h. The employer failed to develop and implement written operating procedures that provided clear instructions including control measures to be taken if physical contact or airborne exposure occurs. Procedure 314FA (314 FA Transfer into 3507FA/FB, No Rev date) does not list control measures to be taken if physical contact or airborne exposure occurs to Cumene such as seeking immediate medical attention should exposure to the eyes, ingestion, or inhalation occur as detailed in the MSDS.
i. The employer failed to develop and implement written operating procedures that provided clear instructions including control measures to be taken if physical contact or airborne exposure occurs. Procedure 3203-E (3203-E Pressure Testing, Rev 5/06/1997) does not list control measures to be taken if physical contact or airborne exposure occurs to Cumene such as seeking immediate medical attention should exposure to the eyes, ingestion, or inhalation occur as detailed in the MSDS.
Citation 1 Item 5
Type of Violation: Serious; $7,000
29 CFR 1910.119(1)(1): The employer shall establish and implement written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.
a. The employer failed to establish written procedures to manage changes for items not considered replacement in kind. The Haverhill Chemicals LLC MOC Procedure, HAV-PSM-PR0-01 0, issued 3115/2012, revision date 3/18/2014, calls for no MOC to be written when the addition of a pipe flange is the only modification. This change would not be a replacement in kind and would require an MOC per the standard. By not establishing procedures to address all process changes, modifications affecting the covered process could be completed without proper analysis and assessment.
b. On or about May 1, 2014, the employer did not ensure the MOC procedure was followed when the Safety Instrumented Systems (SIS) were bypassed in Phenol 2 process unit during de-inventorying of the cleavage reactor.
Citation 1 Item 6
Type of Violation: Serious; $7,000
29 CFR 1910.119(l)(2)(ii): Impact of change on safety and health;
a. The employer failed to assure management of change procedures addressed the impact of the change on safety and health prior to the implementation of said change. PSSR TEAM to install 1 elbow clamp on 450# steam from 3305F (Temporary MOC, MOC Reference Phenol 2_2_2014_9), listed Environmental and Safety Impact: N/A. Being a temporary MOC, health and safety
considerations including, but not limited to high temperature and high pressure steam releases, loss of temporary controls, and leaks should have been considered.
b. The employer failed to assure management of change procedures addressed the impact of the change on safety and health prior to the implementation of said change. PSSR Install spool to replace FI on 3011/JA recycle line (Temporary MOC, MOC Reference Phenol2_2_2013_67), listed Environmental and Safety Impact: N/ A. Safety and health impacts should include, but are not limited to, potential for leaks, loss of temporary control, fugitive emissions, and potential worker exposure.
c. The employer failed to assure management of change procedures addressed the impact of the change on safety and health prior to the implementation of said change. PSSR Clamp old 2 drain vessel piping from 330F to 3011 (Temporary MOC, MOC Reference Phenol2_2_2014_7), listed Environmental and Safety Impact: N/ A. Safety and health impacts should include, but are not limited to, potential for leaks, loss of temporary control, fugitive emissions, and potential worker exposure.
d. The employer failed to assure management of change procedures addressed the impact of the change on safety and health prior to the implementation of said change. PSSR Modify Nozzles and Layout of 216F (MOC Reference Phenol2_2_2013_82,), listed Environmental and Safety Impact: N/A. Safety and health impacts should include, but are not limited to, relieving to a safe locations, potential for emissions from newly installed atmospheric vent, and potential worker exposure.
e. The employer failed to assure management of change procedures addressed the impact of the change on safety and health prior to the implementation of said change. PSSR Modify Nozzles and Layout of 216F (MOC Reference Phenol 2_2_2013 _82,), listed Environmental and Safety Impact: Area is red taped. Safety and health impacts should include, but are not limited to, potential for leaks, fugitive emissions, and potential worker exposure. Where Phenol has a specific gravity of 1.075, it would be likely that concentrations would accumulate at ground level.
Citation 1 Item 7
Type of Violation: Serious; $3,000
29 CFR 1910.305(g)(1)(iv)(B): Where run through holes in walls, ceilings, or floors;
In the BPA Area, in the Breakroom across from the Control Room, a 110 Volt AC extension cord set was dropped through the false ceiling and was being used to provide power to a refrigerator.
Citation 2 Item 1
Type of Violation: Other-than-Serious; $0.00
29 CFR 1910.37(b)(2): Each exit must be clearly visible and marked by a sign reading “Exit.”
a. In the BPA Area, R-1 09 work platform, the exit sign above the door was illegible.
b. In the BPA Area R-11 0 work platform, the exit sign above the door was illegible.
Source:
http://www.osha.gov/ooc/citations/Haverhill_966352_1001_14.pdf
http://www.osha.gov/ooc/citations/Haverhill_975358_1001_14.pdf