On Jan. 19, 2016, the Hartford Area Office cited a chemical manufacturer for 15 serious violations of workplace safety standards. Inspectors found that a manufacturer of swimming pool chemicals and acetone preparations used in nail polish were exposed employees to chemical, fire, and exit access hazards. The company’s manufacturing processes use large amounts of the flammable chemicals acetone and isopropyl alcohol 99 percent. OSHA standards require a workplace to have a program for safely managing processes involving large amounts of these chemicals. The plant lacked a process safety management program. Deficiencies included:
- Not conducting a hazard analysis.
- Having no written operating procedures for each step of the process.
- Not compiling information about process equipment.
- Not inspecting and testing process equipment.
- Not documenting employee training
- Lacking an emergency action program.
Additional chemical and fire hazards involved a locked emergency exit gate, an exit route through a hazardous area, rusted exit stairs, lack of overflow protection for storage tanks, deficient vent piping and not documenting that storage tanks had been strength tested.
Citation 1 Item 1
Type of Violation: Serious; $3,500
29 CFR 1910.24(h): Standard railings were not provided on the open sides of all exposed stairways and stair platforms: A. On or about July 20, 2015, Flammable Room: At mixing tank #5, the open sides of fixed industrial stairs were not provided with an intermediate rail.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 2a
Type of Violation: Serious; $3,500
29 CFR 1910.36(c)(1): Each exit discharge did not lead directly outside or to a street, walkway, refuge area, public way, or open space with access to the outside: A. On or about July 20, 2015, Tank Fill Area, East side of the building: Since no tank deliveries were being made, the security gates to the tank fill area had been locked. Employees escaping from a hazard within the building would be trapped in the area.
Citation 1 Item 2b
Type of Violation: Serious; Grouped
29 CFR 1910.37(a)(2): Exit routes were arranged so that employees would have to travel toward a high hazard area:
A. On or about July 20, 2015, East side of the building: The exit route from the flammable room led to a high hazard area in that ventilation pipes from acetone and isopropyl alcohol 99% tanks in the flammable room vented to the area.
Citation 1 Item 2c
Type of Violation: Serious; Grouped
29 CFR 191037(a)(4): Safeguard(s) designed to protect employees during an emergency (e.g., sprinkler systems, alarm systems, fire doors, exit lighting), were not in proper working order at all times:
A. On or about July 20, 2015, Emergency Exit Route from Flammable Room: The 11-riser fire exit stairs provided as part of the exit route were rusted through. Weeds growing from underneath the stairs obscured holes on the bottom steps.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 3a
Type of Violation: Serious; $3,500
29 CFR 1910.106(b)(2)(vi)(b): Where vent pipe outlets for tanks storing Category 1 or 2 flammable liquids, or Category 3 flammable liquids with a flashpoint below 100 deg F (37.8 deg C), are adjacent to buildings or public ways, they were not located so that the vapors are released at a safe point outside of buildings and not less than 12 feet above the adjacent ground level. In order to aid their dispersion, vapors were not discharged upward or horizontally away from closely adjacent walls. Vent outlets were not located so that flammable vapors were not trapped by eaves or other obstructions and shall be at least five feet from building openings:
A. On or about July 20, 2015, east side of the building outside the flammable room: The vent pipe from acetone tank 5T38 Green was turned 180 degrees and vapors were discharged downward instead of upward or horizontally as required by this section.
Citation 1 Item 3b
Type of Violation: Serious; Grouped
29 CFR 1910.106(b)(4)(iii): Vent piping was not constructed in accordance with paragraph (c) of this section:
A. On or about July 20, 2015, Flammable Area: Vent piping for the tanks of acetone and isopropyl alcohol 99% was not constructed of steel, nodular iron or malleable iron. The vent piping for tanks 5T38 Green and 5T37 Blue was made of PVC, which can distort at 90 degrees C/194 degrees F.
29 CFR 1910.106(c)(2)(i): “Required materials.” Materials for piping, valves, or fittings shall be steel, nodular iron, or malleable iron, except as provided in paragraph (c)(2)(ii), (iii) and (iv) of this section.
Citation 1 Item 4
Type ofViolation: Serious; $3,500
29 CFR 1910.106(b)(4)(iv)(h): Tanks inside buildings were not equipped with a device or other means to prevent overflow into the building: A. On or about July 20, 2015, Flammable Room: Inside storage tanks containing acetone and isopropyl alcohol 99% did not have overflow protection to prevent overflow into the building.
Citation 1 Item 5
Type of Violation: Serious; $4,900
29 CFR 1910.106(b)(7)(i): Tanks not marked in accordance with the American Society of Mechanical Engineers (ASME) code stamp, American Petroleum Institute (API) monogram, or the label of the Underwriters’ Laboratories, Inc. were not strength tested before being placed in service in accordance with good engineering principles and reference was not made to the sections on testing in the codes listed in subparagraphs (1)(iii)(a), (iv)(b), or (v)(b) of this paragraph:
A. On or about July 20, 2015, Flammable Room: In the absence of tank markings, the employer failed to document that flammable storage tanks had been strength tested prior to being placed into service. The 3,000-gallon tanks stored acetone and isopropyl alcohol 99%.
Citation 1 Item 6
Type of Violation: Serious; $4,900
29 CFR 1910.106(f)(3)(i): Tank vehicle and tank car loading or unloading facilities were not separated from aboveground tanks, warehouses, or other plant buildings or nearest line of adjoining property that may be built upon by a distance of 25 feet for Category 1 or 2 flammable liquids, or Category 3 flammable liquids with a flashpoint below 100 degrees F (37.8 degrees C), and 15 feet for Category 3 flammable liquids with a flashpoint at or above 100 degrees F (3 7. 8 degrees C) and Category 4 flammable liquids measured from the nearest position of any fill spout:
A. On or about July 20, 2015, Tank Fill Area: The tank fill nozzle for acetone and isopropyl alcohol 99%, Category 1 flammable liquids was located 12 feet 7 inches horizontally from the flammable room, 13 feet 4 inches diagonally.
Citation 1 Item 7
Type of Violation: Serious; $4,900
29 CFR 1910.119(d)(2)(i): Process safety information pertaining to the technology of the process did not include the elements specified in 29 CFR 1910.l 19(d)(2)(i)(A) through (E):
A. On or about July 20, 2015, Establishment: The employer operated processes using 18,609 pounds of acetone and 15,378 pounds of isopropyl alcohol 99%. The employer had not compiled written process safety information including block flow diagrams, maximum intended inventory or consequences of deviation.
Citation 1 Item 8
Type of Violation: Serious; $4,900
29 CFR 1910.119(d)(3)(i): Process safety information pertaining to the equipment in the process did not include the elements specified in 29 CFR 1910.119(d)(3)(i)(A) through (H):
A. On or about July 20, 2015, Establishment: The employer had not compiled information pertaining to equipment in the process, including materials of construction; piping and instrumentation diagrams (P&IDs); electrical classification; ventilation system design; design codes and standards employed.
Citation 1 Item 9
Type of Violation: Serious; $4,900
29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices:
A. On or about July 20, 2015, Establishment: The employer had not documented that process equipment complied with recognized and generally accepted good engineering practices, in that:
- The employer could not document that the gaskets in the manways on the tanks were compatible with the contents of the tanks.
- The Sandpiper SSB 1-A double diaphragm ·ball valve sanitary pump contained nitrile components that were incompatible with the chemicals run in the process.
- The four 3,000 gallon storage tanks for acetone and isopropyl alcohol 99% used Tygon tubing affixed with screw clamps for tank level gauges.
Acceptable recognized and general accepted good engineering practices, among others, would be National Fire Protection Association (NFPA) 30 – 2015, Flammable and Combustible Liquids Code.
Citation 1 Item 10
Type of Violation: Serious; $4,900
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. On or about July 20, 2015, Flammable Room: The employer had not performed a process hazard analysis on covered processes using 18,609 pounds of acetone and 15,378 pounds of isopropyl alcohol 99%.
Citation 1 Item 11
Type of Violation: Serious; $4,900
29 CFR 1910.119(f)(1): 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 addressing at least steps for each operating phase, safe operating limits, safety and health considerations, and safety systems and their functions as outlined in this paragraph:
A. On or about July 20, 2015, Flammable Room: The employer had not developed written operating procedures for each operating phase including initial startup, normal operations, temporary operations, emergency shutdown, normal shutdown and startup following a turnaround or emergency shutdown; operating limits, steps required to correct or avoid deviation and safety and health considerations, quality control for raw materials and control of hazardous chemical inventory levels.
Citation 1 Item 12
Type of Violation: Serious; $3,500
29 CFR 1910.119(g)(3): The employer did not prepare a record which contained the identity of the employee, the date of training, and the means used to verify that the employee understood the training:
A. On or about July 20, 2015, Flammable Room: The employer had not documented that employees operating equipment in a covered process had been trained and that they understood the training.
Citation 1 Item 13
Type of Violation: Serious; $4,900
29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment:
A. On or about July 20, 2015, Flammable Room: Specific Witten procedures had not been developed or implemented to address regular inspections and preventive maintenance of equipment in covered processes. Equipment used in the processing of isopropyl alcohol 99% and acetone included tanks, pumps, piping, valves, controls for emergency shut down.
NOTE: An effective mechanical integrity program would ensure proper design, fabrication, and installation, recognize equipment deficiencies and perform inspections, tests and perform preventive maintenance.
Citation 1 Item 14
Type of Violation: Serious; $0.00
29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment.
A. On or about July 20, 2015, Flammable Room: The employer had not performed inspections and tests on process equipment, including, but not limited to storage tanks; mixing tanks; valves; pipes; a pneumatic pump; manifold system and agitators used in processes where isopropyl alcohol 99% and acetone were used.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 15a
Type of Violation: Serious; $4,900
29 CFR 1910.119(n): The employer did not establish an emergency plan for the entire plant in accordance with the provisions of29 CFR 1910.38(a):
A. On or about July 20, 2015, Establishment:
- The employer failed to develop and implement an emergency action plan which complied with the provisions of29 CFR 1910.38(a) for employees who work with highly hazardous chemicals, including but not limited to isopropyl alcohol 99% and acetone, to help them escape from a catastrophic event.
- The company had not documented that all employees in the facility had been trained in the employee emergency plan and fire prevention plan.
- There had been no evacuation drills conducted.
- The employer had not defined what constituted a major or minor spill.
- The name and job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties was not clear in that there were several lists of employees to contact in case of emergency, some of whom were no longer employed by the company.
Citation 1 Item 15b
Type of Violation: Serious; Grouped
29 CFR 1910.120(q)(1): An employer who will evacuate their employees from the danger area when an emergency occurs, and who do not permit any of their employees to assist in handling the emergency, had not provided an emergency action plan in accordance with 29 CFR 1910.38:
A. On or about July 20, 2015, Flammable Room:
- The company had not documented that all employees in the facility had been trained in the employee emergency plan and fire prevention plan.
- There had been no evacuation drills conducted.
- The employer had not defined what constituted a major or minor spill.
- The name and job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties was not clear in that there were several lists of employees to contact in case of emergency, some of whom were no longer employed by the company.
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