OSHA issued eleven (11) PSM citation at a business that specializes in heat treating powder metal parts. The September 2014 inspection was initiated under the National Emphasis Program for Process Safety Management at chemical facilities. The process used anhydrous ammonia as a fuel at the metal heat treating facility. Here is a breakdown of the 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(c)(l): Employers did not develop a written plan of action regarding the implementation of the employee participation required by this paragraph.
- The employer did not develop a written plan of action regarding the implementation of employee participation for the covered process at the facility.
Citation 1 Item 2a
Type of Violation: Serious; $7,000
29 CFR 1910.119(d)(2)(i)(D): The employer did not ensure that information concerning the technology of the process included safe upper and lower limits for such items as temperature, pressure, flows or compositions.
- The employer did not ensure that the information regarding the technology of the covered process at the facility such as ammonia dissociation included safe upper and lower limits for items as temperatures, pressures, flows or compositions.
Citation 1 Item 2b
Type of Violation: Serious
29 CFR 1910.119( d)(2)(i)(E): The employer did not ensure that the information concerning the technology of the process included an evaluation of the consequences of deviations, including those affecting the safety and health of employees.
- The employer did not ensure that the information concerning the technology of the covered processes at the facility included an evaluation of the consequences of deviation, including those affecting the safety and health of employees.
Citation 1 Item 3a
Type of Violation: Serious; $7,000
29 CFR 1910.119(e)(3)(iii): The process hazard analysis did not address the engineering and administrative controls applicable to the hazards and their interelationship, such as, appropriate application of detection methodologies to provide early warning of releases: (Acceptable detection method might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.)
- The employer’s January 13, 2011 and April 30, 2014 process hazard analyses (PHA) did not identify the appropriate safeguards to control high consequences hazards for the ammonia dissociators. The employer used administrative controls such as procedures to safeguard against catastrophic hazards where engineering controls such as automatic shutoffs should have been used.
- The employer’s January 13, 2011 and April 30, 2014 process hazard analyses (PHA) did not identify the appropriate safeguards to control high consequences hazards such as:
- an ammonia leak from the process piping located inside the facility and at ammonia dissociators.
- an ammonia pipe located inside the facility getting damaged.
- a power failures, including total, brief, partial, or brownout on the ammonia dissociators.
- a failure of the hydrogen fueled furnaces and the resulting levels hydrogen, below the upper explosive limit, on the upstream ammonia dissociators.
- a loss of pressure in the ammonia system including the ammonia dissociators.
Citation 1 Item 3b
Type of Violation: Serious
29 CFR 1910.119(e)(3)(v): The process safety hazard analyses did not address facility siting.
- The employer’s January 13, 2011 and April 30, 2014 process hazard analyses (PHA) did not address for the process of ammonia dissociation, the facility siting, which included, but are not limited to:
- The spacing between components in the furnace area.
- The location of large inventories of ammonia in the outside and inside storage area.
- The location of furnaces, weld shops, forklift traffic and other likely sources of ignition.
- The location of the truck dock in relation to the ammonia storage tanks.
- The electrical classification of the facility.
Citation 1 Item 3c
Type of Violation: Serious
29 CFR 1910.119(e)(3)(vi): The process hazard analyses did not address human factors.
- The employer’s January 13, 2011 and April 30, 2014 process hazard analyses (PHA) did not address human factors affecting the process of ammonia dissociators such as but not limited to, the following:
- Lack of trained maintenance personnel or lead supervisors;
- Coverage when trained employees are on leave;
- Operator overload during normal operations, emergency operations and emergency shutdown.
Citation 1 Item 3d
Type of Violation: Serious
29 CFR 1910.119(e)(3)(vii): The process hazard analyses did not address a qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace.
- The employer’s January 13, 2011 and April 30, 2014 Process Hazard Analyses (PHA) did not address an evaluation of possible safety and health effects due to failure of each control on employees such as employee exposures to inhalation hazards in case of a chemical release.
Citation 1 Item 4
Type of Violation: Serious; $7,000
29 CFR 1910.119(f)(1)(iv): The employer did not 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 addressed the safety systems and their functions.
- The operating procedures for #224, 226, and 228 Dissociator Start Up and Shut down did not adequately address safety systems such as specific alarms levels and the lack of automatic shutdown for the dissociators.
Citation 1 Item 5
Type of Violation: Serious; $7,000
29 CFR 1910.119(g)(1)(i): The employer did not ensure each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, were trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section.
- The maintenance personnel and lead supervisors for the ammonia dissociators did not receive process overview training prior to being required to operate the process. The employees did not receive overview training on the hazards of the process, standard operating procedures, chemicals in the process and protective measures in place.
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 an overview of that process and its hazards and in the procedures applicable to the employee’s job tasks to assure that the employee could perform the job tasks in a safe manner.
- The employer did not train employees involved in maintaining the on-going integrity of process equipment in the inspection process and procedures required to perform the job tasks for the covered process at the facility.
Citation 2 Item 1
Type of Violation: Other-than-Serious; $0.00
29 CFR 1910.119(n): The employer did not establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.3 8. In addition, the emergency action plan shall include procedures for handling small releases.
- The employer did not establish or implement an emergency action plan that included procedures for handling small releases.
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