On July 22, OSHA issued eight serious safety citations from an inspection that was NOT initiated as a PSM inspection, but after determining that the company was using flammable liquids above the threshold quantities that could present a potential for a catastrophic event. Business was cited for not implementing five elements of the PSM standard, including process hazard analysis, operating procedures and training; and not preventing the sudden startup or movement of equipment during service and maintenance, a procedure known as lockout/tagout. Proposed Penalties are $50,400. Here is a breakdown of the citations:
Citation 1 Item 1
Type of Violation: Serious; $6,300
29 CFR 1910.119(c)(1): The employer did not develop a written plan of action regarding the implementation of the employee participation required 29 CFR 1910.119:
a) Compounding Area
The employer had no written plan of action for employee participation in process safety management.
Employees manufactured perfume and cologne using denatured alcohol, a flammable liquid. Processes occurring during the inspection included, but were not limited to pumping and mixing/agitation of flammable liquids. The quantity of flammable liquids in the process is 14,000 lbs.
The employer shall consult with employees on the conduct and development of process hazards analyses and development of the other elements of process safety management.
Citation 1 Item 2a
Type of Violation: Serious; $6,300
29 CFR 191O.119(d)(2)(i)(D): Process safety information pertaining to the technology of the process did not include the safe upper and lower limits for such items as flows:
a) Compounding Areas
The employer did not develop process safety information pertaining to the technology of the processes used by employees in the manufacture of perfume/cologne including the safe upper and lower limits for the transfer meter pump’s flow rate.
Employees manufactured perfume/cologne using denatured alcohol, a flammable liquid. Processes occurring during the inspection included, but were not limited to, pumping and mixing/agitation of 14,000 lbs of flammable liquids.
Citation 1 Item 2b
Type of Violation: Serious
29 CFR 1910.119(d)(2)(i)(E): Process safety information pertaining to the technology of the process did not include an evaluation of the consequence of deviations, including those affecting the safety and health of employees:
a) Compounding Areas
The employer did not evaluate the consequences of deviation during transfer of flammable liquids from storage tanks to process vessels. Deviation during transfer could include overflow of process vessels.
Employees manufactured perfume/cologne using denatured alcohol, a flammable liquid. Processes occurring during the inspection included, but were not limited to, pumping and mixing/agitation of 14,000 lbs of flammable liquids.
Citation 1 Item 3
Type of Violation: Serious; $6,300
29 CFR 1910.119(d)(3)(i)(B): Process safety information pertaining to the equipment in the process did not include the piping and instrumentation diagrams (P&IDs):
a) Compounding Area
The employer did not have the required P&IDs for the process equipment.
Employees manufactured perfumes/colognes using denatured alcohol, a flammable liquid. Processes occurring during the inspection included, but were not limited to, pumping and mixing/agitation of 14,000 lbs of flammable liquids.
Citation 1 Item 4
Type of Violation: Serious; $6,300
29 CFR 191O.ll9(e)(1): The employer did not perform an initial process hazard analysis (hazard evaluation) on processes covered by 29 CFR 1910. 119:
a) Compounding area
The employer did not perform an initial process hazard analysis on the covered process used by employees in the manufacture of perfume/cologne, including but limited to pumping and mixing/agitation of flammable liquids. The quantity of flammable liquid in the covered process is 14,000 lbs.
Each process used in the manufacture of nail polish must receive a Process Hazard Analysis (PHA). The PHA must be performed by a team with expertise in engineering and process operations. The team must include at least one employee with experience and knowledge specific to the process and one individual knowledgeable in the specific PHA methodology being used.
The PHA must be performed using a methodology such as What-If, Checklist, What-If/Checklist, Hazard and Operability Study, Failure Mode and Effects Analysis, Fault Tree Analysis or equivalent. The PHA must address the hazards of the process, the identification of any previous incident which had a likely potential for catastrophic consequences in the workplace, engineering and administrative controls applicable to the hazards, consequences of failure of engineering and administrative controls, facility siting, human factors and possible safety and health effects of failure of controls on employees in the workplace.
The team’s findings and recommendations must be promptly addressed and the corrective actions documented.
The PHA must be updated and revalidated by a team at least every five years.
Citation 1 Item 5
Type of Violation: Serious; $6,300
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 the safety information and which address the elements listed in 29 CFR 191O.119(f)(1)(i) through (f)(1)(v):
a) Compounding Area
The employer did not develop and implement written operating procedures, including but not limited to, emergency shut down, temporary operations, and start up after emergency shutdown . Employees manufactured perfume/cologne using denatured alcohol, a flammable liquid. Processes occurring during the inspection included, but were not limited, pumping and mixing/agitation of flammable liquids. The quantity of the flammable liquids in the process is 14,000 lbs.
Citation 1 Item 6
Type of Violation: Serious; $6,300
29 CFR 191O.l19(g)(1)(i): The employer did not train each employee involved in the operating process, in a overview of the process and in the operating procedures as specified in paragraph (f) of 29 CFR 1910.119:
a) Compounding areas
Employees manufactured perfume/cologne 11sing alcohol, a flammable liquid, without receiving training in the general requirements of the process safety standard. Processes occurring during the time of the inspection included, but were not limited to, pumping, and mixing/agitation of flammable liquids. The quantity of flammable liquids in the process is 14,000 lbs.
Citation 1 Item 7
Type of Violation: Serious; $6,300
29 CFR 1910.119(j)(2): The employer did not establish or implement written procedures to maintain the on-going integrity of process equipment:
a) Compounding area
The employer did not establish and implement written mechanical integrity procedures for employees responsible for maintenance of process equipment, including but not limited to conservation vent/flame arrestor, as part of the safety system. Employees manufactured perfume/cologne, a flammable liquid. Processes occurring during the inspection includes, but were not limited to, pumping and mixing/agitation of flammable liquids. The quantity of the flammable liquids in the process is 14,000 lbs.
Citation 1 Item 8
Type of Violation: Serious; $6,300
29 CFR 1910.147(c)(4)(i): Procedures were not utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:
a) Line# 10 – Employees were repairing main drive of Line #10 motor without locking out energy sources.
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