OSHA has cited a paper mill for failing to protect workers from hazards associated with exposure to sulfur dioxide. SO2 is used in treating wood pulp for paper manufacturing and can cause numerous adverse effects to the respiratory tract when vapors are inhaled. OSHA cited eight violations, carrying proposed penalties of $42,300. OSHA opened the inspection Jan. 30 under the National Emphasis Program for chemicals and cited the mill for seven serious violations. Six of those violations involve OSHA’s PSM standard. Another serious violation was cited for failing to conduct an annual audit of the lockout/tagout procedures at the facility. Here is a 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 1a
Type of Violation: Serious; $5,500
29 CFR 1910.l19(d)(2)(i): Information concerning the technology of the process was not provided:
(a) Sulfur Dioxide PSM Covered Process; Process Safety Information pertaining to the technology of the process was not provided based on 29 CFR 1910.119(d)(2)(i)[B] and 1910.119(d)(2)(i)[D]-[E] which includes process chemistry; safe upper and lower limits for items such as temperatures, pressures, flows or compositions; as well as, evaluation of the consequences of deviations affecting the safety and health of employees.
Citation 1 Item 1b
Type of Violation: Serious; GROUPED
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)[B] through [H]:
(a) Sulfur Dioxide PSM Covered Process; Process Safety Information pertaining to the equipment of the process was not provided, or was incomplete, based on 29 CFR 1910.119(d)(3)(i)[B]-[H] which includes Piping and Instrument Diagrams (P&ID’s);electrical classification; relief system design and design basis; ventilation system design; design codes and standards; material and energy balances; and safety systems (e.g. interlocks, detection or suppression systems).
(b) Sulfur Dioxide PSM Covered Process; Piping and Instrument Diagrams (P&ID) were not updated to reflect all equipment on the system; an Electric POWER actuator (s/n AY05924) was not identified on P&ID 12PID006 Sulfur Dioxide Storage System.
Citation 1 Item 1c
Type ofViolation: Serious; GROUPED
29 CFR 1910.119( d)(3)(ii): The employer did not ensure that equipment complied with recognized and generally accepted good engineering practices: (a) Sulfur Dioxide PSM Covered Process, Storage Tank; The employer did not ensure the pressure safety relief system complied with recognized and generally accepted good engineering practices (Compressed Gas Association G-3 1995- Section 10.3) based on the fact that discharge lines relieved to an unsafe location where employees worked daily.
(b) Sulfur Dioxide PSM Covered Process; The employer did not ensure that equipment such as, but not limited to, the expansion chambers, rupture discs, piping, etc. complied with recognized and generally accepted good engineering practices.
Citation 1 Item 2a
Type of Violation: Serious; $7,000
29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the team’s findings and recommendations to ensure the recommendations were resolved in a timely manner; the resolutions were documented based on actions to be taken; a written schedule of when actions were to be completed; and communication to employees whose work assignment may have been affected by the recommendations or actions:
(a) Sulfur Dioxide PSM Covered Process; The.employer failed to develop a system to address identified deficiencies noted during the 2012 Process Hazard Analysis; there were approximately 23 identified recommendations that were not addressed in a timely manner and documented to resolution.
Citation 1 Item 2b
Type of Violation: Serious; GROUPED
29 CFR 1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected:
(a) Sulfur Dioxide PSM Covered Process; The employer failed to develop a system to address identified deficiencies noted during the 2009 and 2012 process safety compliance audit, several items from the 2009 audit were repeat items on the 2012 audit. There were approximately 49 identified recommendations in the 2012 audit that were not addressed in a timely manner and documented to resolution.
Citation 1 Item 3a
Type of Violation: Serious; $7,000
29 CFR 1910.119(f)(1)(i)(D): The employer did not develop and implement written operating procedures that provide clear instructions for emergency shutdown, including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner:
(a) Sulfur Dioxide PSM Covered Process; Written emergency operating and shutdown procedures were not developed and implemented to provide clear instructions to Bailey Operators and other affected personnel.
Citation 1 Item 3b
Type of Violation: Serious; GROUPED
29 CFR 1910.119(f)(1)(ii): 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 29 CFR 1910.119(f)(1)(ii)[A]-[B] and identified process safety information that addressed operating limits:
(a) Sulfur Dioxide PSM Covered Process; Standard Operating Procedures such as, but not limited to, the Receipt and Unloading of Sulfur Dioxide, Adding Sulfur Dioxide to the Hot Acid Accumulator, Adding Sulfur Dioxide to the Acid Towers, and Response and Emergency Shutdown of Sulfur Dioxide Equipment were incomplete and did not include necessary information on operating limits, consequences of deviation, and steps required to correct or avoid deviations outside of operating parameters.
Citation 1 Item 3c
Type of Violation: Serious; GROUPED
29 CFR 1910.119(f)(3): The operating procedures were not certified annually to ensure that they were accurate and reflected current operating practice:
(a) Sulfur Dioxide PSM Covered Process; The standard operating procedures for Receipt and Unloading of Sulfur Dioxide (1/11/12) was not updated and certified annually to reflect recommendations considered in the 2012 PHA. Other noted deficiencies included, but are not limited to, the requirement of unloading personnel to don proper personal protective equipment, notification to the Bailey Operators when the unloading process is complete, announcement over the intercom that unloading is taking place, inspection of the drivers truck to ensure the emergency stop works on the tank, and inspection of the drivers hose to ensure adequacy (consistent with the Compressed Gas Association G-3 1995- Section 10.5).
(b) Sulfur Dioxide PSM Covered Process; The standard operating procedures for Response and Emergency Shutdown of Sulfur Dioxide Equipment (1/11112) was not updated and certified annually to reflect the steps for each operating phase of an emergency shutdown to include authorized personnel, the Bailey Operators, recent release history and response, as well as, isolation of a leak in each of the covered process areas.
(c) Sulfur Dioxide PSM Covered Process; The standard operating procedures for Adding Sulfur Dioxide to the Hot Acid Accumulator (11/28/2012) and Adding Sulfur Dioxide to the Acid Towers (11/28/2012) were not updated and certified annually to ensure the procedures were current and accurate.
Citation 1 Item 4a
Type of Violation: Serious; $5,500
29 CPR 1910.119(g)(2): Refresher training was not provided at least every three years to each employee involved in operating a process to ensure that the employee understands and adheres to the current operating procedures of the process:
(a) Sulfur Dioxide PSM Covered Process; The employer did not provide refresher training, at least every three years, to Bailey Operators and other affected employees involved with the PSM covered processes to ensure the employee(s) understood and adhered to operating procedures.
Citation 1 Item 4b
Type of Violation: Serious; GROUPED
29 CFR 1910.119(g)(3): The employer did not maintain a record of training for employees operating or involved with a covered process:
(a) Sulfur Dioxide PSM Covered Process; Documented training was not provided or was incomplete; therefore, confirmation of training for the Bailey Operators and other affected employees involved with the PSM covered processes could not be ascertained.
Citation 1 Item 5a
Type of Violation: Serious; $3,300
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) Sulfur Dioxide PSM Covered Process; The employer did not evaluate selected contractors (i.e. XXXXXXXXXXXXXXXX, Inc., XXXXXX Inc., XXXXXXXXXX Inspection, Inc., XXXXXXXXXX Compressor and Equipment, XXXXXXX Fabrication & Manufacturing, Inc., etc.) safety performance prior to working on or near the covered process.
Citation 1 Item 5b
Type of Violation: Serious; GROUPED
29 CFR 1910.119(h)(2)(v): The employer did not periodically evaluate the performance of contract employers to ensure they were fulfilling their obligations as specified in 29 CFR 1910.119(h)(3):
(a) Sulfur Dioxide PSM Covered Process; The employer did not periodically evaluate the performance of contract employers in fulfilling their obligations which included, but is not limited to, XXX Chemical Solutions, Inc., XXXXX Inc., XXXXXXX Inspection, Inc., XXX Compressor and Equipment, XXXXXXXX Fabrication & Manufacturing, Inc., etc.)
Citation 1 Item 6a
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment:
(a) Sulfur Dioxide PSM Covered Process; Written maintenance procedures were not provided, or were incomplete, for process equipment which included, but is not limited to, pressure safety relief valves, pumps, expansion chambers, rupture discs, pressure switches, piping and valves, transmitters, etc.
Citation 1 Item 6b
Type of Violation: Serious; GROUPED
29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment, to maintain mechanical integrity, was not consistent with applicable manufacturer’s recommendations and good engineering practices:
(a) Sulfur Dioxide PSM Covered Process; The employer did not ensure the frequency of inspections and tests were consistent with manufacturers recommendations and good engineering practices for equipment such as, but not limited to, XXXXX Rupture Discs; XXXXXXX Pressure Switches; XXXXXXX Fabrication and Manufacturing Tank Car Safety System, equipment included, but is not limited to, the primary and secondary differential pressure switches; XXXXXX Control System and Alarms, equipment included, but is not limited to, the sulfur dioxide fill line rupture disc alarm, tank outlet rupture disc alarm, sulfur dioxide tank fill shutoff, etc.; Tank Level Transmitter; Piping and Valves (specific to the Compressed Gas Association G-3 1995- Section 10.2 and 10.2.1); XXXXXXXX Pressure Indicating Transmitter; and the Crosby Pressure Safety Relief Valves s/n VA0121225-0l and 82314000.
Citation 1 Item 6c
Type of Violation: Serious; GROUPED
29 CFR 1910.119(j)(4)(iv): The employer did not document each inspection and test that had been performed on process equipment. The documentation did not identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test:
(a) Sulfur Dioxide PSM Covered Process; The employer did not document, or adequately document, each inspection and test that had been performed on process equipment which included, but is not limited to, pressure safety relief valves, pumps, expansion chambers, rupture discs, pressure switches, inspection of piping and valves; transmitters, etc.
Citation 1 Item 6d
Type of Violation: Serious; GROUPED
29 CFR 1910.119(j)(5): The employer did not connect deficiencies in equipment that were outside acceptable limits:
(a) Sulfur Dioxide PSM Covered Process, Powell Fabrication and Manufacturing Tank Car Safety System; The employer did not correct a deficiency in equipment noted during a recent inspection on June 5, 2013 (i.e. dew point sensor is not at line pressure but is in a sample line that bleeds to atmosphere).
(b) Sulfur Dioxide PSM Covered Process;· Crosby Pressure Safety Relief Valve s/n VAO 121225-01 type 2J3-JOS1.5 (repaired last by Allied Valve 6/14/2012) and Crosby Pressure Safety Relief Valve s/n 82314000 type 2J3-JOS 1. 5 (repaired last by Ferguson Enterprises 11/20/2008) were not changed out annually.
Citation 1 Item 7a
Type ofViolation: Serious; $7,000
29 CFR 1910.147(c)(6)(i): The employer did not conduct a periodic inspection of the energy control procedure(s) at least annually to ensure that the procedure and the requirement of this standard were being followed:
(a) Sulfur Dioxide PSM Covered Process; The employer did not conduct a periodic inspection of energy control procedures at least annually to ensure the procedures were accurate, employees were knowledgeable on the procedures, and the requirements of this standard were being followed.
Citation 1 Item 7b
Type of Violation: Serious; GROUPED
29 CFR 1910.147(c)(6)(ii):The employer did not certify that periodic inspections of the energy control procedures had been performed:
(a) Sulfur Dioxide PSM Covered Process; The employer did not certify that a periodic inspection of the energy control procedures had been conducted.
Citation 2 Item 1
Type of Violation: Other-than-Serious; $0
29 CFR 1910.119(h)(2)(vi): The employer did not maintain a contract employee injury and illness log related to the contractor’s work in process areas: (a) Sulfur Dioxide PSM Covered Process; The employer did not maintain a separate contractor employee injury and illness log related to contract work in process areas.
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