OSHA Inspection: D P C INDUSTRIES, INC.

Issued

Feb 16, 1990

Abate by

May 15, 1990

Penalty

Initial $360 · Current $360

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The
employer did not furnish employment and a place of employment which were
free from recognized hazards that were causing or likely to cause death
or serious physical harm to employees in that employees were exposed to
chlorine, sulfur dioxide and ammonia inhalation from the transfer and
packaging operations involved with these chemicals. The employer did not
establish or implement a comprehensive safety systems evaluation for
prevention of chlorine, sulfur dioxide and ammonia leaks.
Among other methods, the following are feasible and acceptable abatement
methods to correct these hazards:
1) Implement written comprehensive Hazard Evaluation Procedures (e.g.
Dow and Mond Hazard indicies, Preliminary Hazard Analysis (PHA),
"What If" Method, Hazard and Operability Study (HAZOP), Failure Modes
Effects and Criticality Analysis (FEMCA), Fault Tree Analysis (FTA),
Event Tree Analysis (ETA), Cause Consequence Analysis (CCA) and HUMAN
Error Analysis;
2) Implement a written procedure detailing a preventative maintenance
schedule for applicable parts of the chlorine, sulfur dioxide and
ammonia systems (e.g. pipes, valves, pumps and etc);
3) Install remote control valves which are capable of isolating and/
or shutting down critical valves on the chlorine, sulfur dioxide and
ammonia system;
4) Perform and critique and adequate number of "mock drills" to
include potential emergency scenarios;
5) Implement a written formal procedure to periodically measure both
the water and oxygen content of the ammonia in storage vessels which
are subject to Stress Corrosion Cracking (SCC);
6) Implement written procedures including an appropriate timetable
for Non-Destructive Testing (NDT) of equipment currently in use which
is subject to corrosion; and
7) Install monitoring devices equipped with appropriate alarm
mechanisms for the detection of chlorine, sulfur dioxide and ammonia.

Issued

Feb 16, 1990

Abate by

Mar 15, 1990

Penalty

Initial $120

Issued

Feb 16, 1990

Abate by

Mar 14, 1990

Issued

Feb 16, 1990

Abate by

Mar 14, 1990

Issued

Feb 16, 1990

Abate by

Apr 15, 1990

Issued

Feb 16, 1990

Abate by

Feb 22, 1990

Issued

Feb 15, 1990

Abate by

Mar 14, 1990

Issued

Feb 15, 1990

Abate by

Mar 14, 1990