OSHA cited a paper product manufacturer for exposing employees to hot steam and failing to ensure the use of proper hazardous energy control methods. The company faces $211,400 in proposed fines. OSHA launched an investigation of the facility after hot steam burned an employee trying to repair a leak on a steam-line header. OSHA determined the header had been leaking for several months and found the company violated federal safety standards for personal protective equipment (PPE), lockout/tagout, and process safety management (PSM). Here is a break down of the citations:
Citation 1 Item 1
Type of Violation: Serious; $6,251
29 CFR 1910.119(d)(2)(i)(A): Information concerning the technology of the process did not include a block flow diagram or simplified process flow diagram:
(a) On or about February 20, 2019, the block flow diagram for the methanol (MeOH) system did not accurately reflect the process when it showed a process water line connected to the MeOH piping in the MeOH storage area.
Citation 1 Item 2
Type of Violation: Serious; $6,251
29 CFR 1910.119(d)(3)(i)(B): Information concerning the equipment of the process did not include complete and accurate piping and instrument diagram:
On or about February 20, 2019 piping and instrument diagrams (P&IDs) were inaccurate and/or incomplete.
(a) Valve labeling on P&ID 5060-T-12 Sheet 1 Rev 10 is incomplete. Several valves on the diagram are identified as V-XXX.
(b) P&ID 5067-T-12 Sheet 8 Rev 21 for the Methanol system did not accurately represent the process.
Citation 1 Item 3
Type of Violation: Serious; $13,260
29 CFR 1910.119(d)(3)(i)(D): Process safety information pertaining to the equipment in the process did not include relief system design and design basis:
On or about February 20, 2019, the process safety information for the Chlorine Dioxide SVP process did not include relief system design basis:
(a) The design basis for VLVS-0085 in the relief system of the chlorine dioxide SVP was not included in PSI for the process.
(b) The design basis for VLVS-0087 in the relief system of the chlorine dioxide SVP was not included in PSI for the process.
(c) The design basis for VLVS-0122 in the relief system of the chlorine dioxide SVP was not included in PSI for the process.
(d) The design basis for VLVS-0123 in the relief system of the chlorine dioxide SVP was not included in PSI for the process.
(e) The design basis for VLVS-0124 in the relief system of the chlorine dioxide SVP was not included in PSI for the process.
(f) The design basis for VLVS-0169 in the relief system of the chlorine dioxide SVP was not included in PSI for the process.
(g) The design basis for VLVS-3083 in the relief system of the chlorine dioxide SVP was not included in PSI for the process.
Citation 1 Item 4
Type of Violation: Serious; $13,260
29 CFR 1910.119(f)(3): The operating procedures were not reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer did not certify annually that these operating procedures were current and accurate.
On or about February 20, 2019, the employer did not certify annually the existing emergency SVP process shutdown procedures for quickly and effectively shut down critical process equipment.
Citation 1 Item 5
Type of Violation: Serious; $13,260
29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were 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 were taken to assure safe operation:
In The Alternative 29 CFR 1910.119(j)(6)(ii): The employer did not perform appropriate checks and inspections to assure that equipment is installed properly and consistent with design specifications and the manufacturer instructions.
The employer did not correct deficiencies in equipment that were outside acceptable limits and did not implement interim measures to ensure the safety of the equipment.
(a) On or about January 16, 2019, and at times prior thereto, the employer did not repair a known through-wall piping defect in the steam blowdown header that allowed an uncontrolled high-temperature steam leak into an area of the powerhouse where workers were required to enter and work.
(b) On or about February 20, 2019, and at times prior thereto Flange MeOH 0013A in the methanol piping was not properly bolted. The flange did not have all the fastening bolts installed.
(c) On or about February 20, 2019, and at times prior thereto Bolting materials for flange MeOH 0021A in the methanol area were not of the material specified in the piping specification for Methanol Piping.
(d) On or about February 20, 2019, and at times prior thereto Bolting materials for flange MW IA in the methanol area were not of the material specified in the piping specification for Methanol Piping.
(e) On or about February 20, 2019, and at times prior thereto Bolting materials for flange MeOH 0021B in the methanol area were not of the material specified in the piping specification for Methanol Piping.
(f) On or about February 20, 2019, and at times prior thereto Flange MeOH 0005 in the methanol area was not of the material specified in the piping specification for Methanol Piping.
(g) On or about January 16, 2019, and times prior, the employer did not promptly repair a leak in the powerhouse blowdown header, exposing Process Tenders (PTs) and Area Operators (AOs) to burns from unexpected releases of thermal energy as they checked equipment near the leak;
(h) On or about January 16, 2019, and times prior, the employer did not promptly repair a leak in the powerhouse blowdown header, exposing maintenance employees to burns from unexpected releases of thermal energy as they staged a clamp to repair the leak.
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 1a
Type of Violation: Serious; $13,260
29 CFR 1910.132(d)(1): The employer did not assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE):
(a) On or about January 16,201, and times prior, the employer did not assess the workplace to determine what personal protective equipment is required for employees installing a clamp for the blowdown header in the powerhouse, exposing employees to burns for exposure to steam.
Citation 1 Item 1b
Type of Violation: Serious; Grouped
29 CPR 1910.133(a)(1): The employer did not ensure that each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation:
(a) On or about January 16, 2019, and times prior the employer did not ensure that employees installing clamp on the blowdown line in the powerhouse used appropriate face protection to protect them from burns.
Citation 1 Item 1c
Type of Violation: Serious; Grouped
29 CFR 1910.138(a): The employer did not select and require employee(s) to use appropriate hand protection when employees’ hands were exposed to hazards such as those from skin absorption of harmful substances; severe cuts or lacerations; severe abrasion; punctures; chemical burns; thermal bums; and harmful temperature extremes:
(a) On or about January 16, 2019, and times prior, the employer did not select and require employees to use thermally resistant hand protection while employees were installing a clamp for the blowdown header in the powerhouse, exposing employees to burns.
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; $13,260
29 CFR 1910.147(d)(1): The authorized employee did not have knowledge of the type and magnitude of the energy, the hazards of the energy to be controlled, and the method or means to control the energy before the authorized or affected employee turned off:
(a) On or about January 16, 2019, and times prior, the employer did not identify and isolate all of the valves necessary to bring the blowdown header in the powerhouse to a zero energy state before installing a clamp to be placed on a damaged portion of the blowdown header, exposing employees to burns associated with the unexpected release of thermal energy.
Citation 1 Item 2b
Type of Violation: Serious; Grouped
29 CFR 1910.147(d)(4)(i): Lockout or tag out devices were not affixed to each energy-isolating device by authorized employees:
(a) On or about January 16, 2019, and times prior, the employer did not ensure that lockout devices were affixed to all sources of hazardous energy while powerhouse maintenance employee s installing a clamp to be placed on a damaged blowdown header, exposing employees to burns associated with the unexpected release of thermal energy.
Citation 2 Item 1
Type of Violation: Willful; $132,598
29 CFR 1910.147(c)(4)(i): Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:
(a) On or about January 16, 2019, and times prior, the employer did not develop, document and /or utilize specific energy control procedures for installing and affixing a clamp on a blowdown header in the powerhouse, exposing employees to second and third-degree burns from steam.
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