OSHA Inspection: C-Z CHEMICAL CO., DIV. OF ROCHESTER MIDLAND

Issued

Oct 24, 1989

Abate by

Nov 24, 1989

Penalty

Initial $480 · Current $360 Reduced

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, inhalation of toxic gases
such as nitrogen trichloride, chlorine and carbon monoxide; severe burns
and death from increased likelihood of fire and/or explosion due to
improper premixings of dry chlorinating compound (OLIN CDB Clearon) with
organic matter (Belzak glucoheptonate) resulting in runaway chemical
reaction. Conditions noted at the time of inspection which contributed
to this hazard are as follow:
a) Inadequate process hazard review which failed to consider all
components involved in the manufacture of Rochester Midland HCP-650
Plus and which would identify ways by which an uncontrolled reaction
could occur.
b) Inadequate and inconsistant production procedures for the manufacture
of Rochester Midland HCP-650 Plus which failed to emphasize the
hazard associated with premixing OLIN CDB Clearon with Belzak
glucoheptonate and sodium hydroxide and did not specify steps for
proper sequence addition of chemicals into the mixer.
c) Operators and supervisors, where Rochester Midland HCP-650 Plus is
manufactured, were not sufficiently trained on the reaction process
and procedures to follow for proper blending.
Among other methods, one feasible and acceptable abatement method to
correct this hazard is to establish administrative and engineering
controls over the work being performed, including but not necessarily
limited to the following provisions:
a) Chemical Process Hazard Review
Conduct a chemical process system safety hazard review that will
identify process deficiencies and upsets plus estimate their
frequency and probable consequences.
Operating parameters, procedures and/or process control
instrumentation determined by this review to be critical for the safe
processing of Rochester Midland HCP-650 Plus shall be designed and
constructed for either redundancy or back-up to assure maximum
feasible safety to employees. This review shall be of a type
generally recognized in the chemical processing industries (such as
What If, Cause/Consequence, FMEA, HAZOP, Fault Tree, etc.,) and shall
include, but not necessarily be limited to, the following:
i) Preparation and review of process flow sheets to determine possible
emergencies during start-up, normal operating and shutdown
conditions and to evaluate the consequencesof excessive temperature
pressure, or variations in material controls.
ii) Review of raw meterials MSDSs, product bulletins, technical and
scientific literature considering fire, explosion, health, stability
and reactivity characteristics including handling, storage,
emergency procedures and special precautions (highly humid
environments).
b) Standard Operating Procedures
i) Modify written detailed descriptions and Standard Operating
Procedures for the manufacture of Rochester Midland HCP-650 Plus
to assure safe start-up and processing within controllable limits
and to provide for safe shutdown of equipment in the event of
abnormal conditions (highly humid environments).

Issued

Sep 25, 1989

Abate by

Jan 1, 1990

Penalty

Initial $480 · Current $360 Reduced

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:
Employees were exposed to crushing/amputation hazards due to
unanticipated machine movement of mixers, tumblers, augers, etc.
during maintenance and repair.
Among other methods, one feasible and acceptable abatement method to
correct these hazards is to establish and enforce an adequate lockout/-
tagout of energy sources in accordance with ANSI Z244.1-1982, "American
National Standard for Personnel Protection - Lockout/Tagout of Energy
Sources - Minimum Safety Requirements". Essential elements of this
lockout/tagout procedure would include:
1) Require lock-out before any maintenance, inspection, clearing,
adjusting or servicing that requires employees to enter or be in
close contact with moving machinery or equipment.
2) Require that each exposed employee lock-out the energy isolating
device with his/her personal lock.
3) Maintain available operation and maintenance manuals on all machinery
or equipment to be serviced. Assure that these manuals and other
appropriate information are provided to employees before work is
begun.
4) Establish and use a documented work order system for machinery
maintenance and repairs which includes Supervisors' approval to
reactivate machinery or equipment after servicing.
5) Disconnect or isolate machinery or equipment by positioning the
switch, valve or other energy isolating device so that energy sources
(e.g. electrical, mechanical, hydraulic, etc.) are deactivated.
Stored energy such as that in capacitors, springs, elevated machine
members, rotating flywheels, hydraulic systems, and gas, air, steam,
or water pressure, etc., must be dissipated or restrained by methods
such as grounding, repositioning, blocking, bleeding down, etc.
6) Test machinery or equipment to ensure that the energy sources have
been effectively disconnected or isolated. As a precautionary
measure, return the operating controls to the "OFF" position after
the test has been completed.
NOTE: The test shall only be performed after ensuring that no
employees are exposed in the machine or equipment area.
7) Remove locks only after ensuring the safety of all exposed
employees.
8) Train employees responsible for machinery or equipment lockout in
all elements of the program. This training shall be repeated as
frequently as necessary to maintain management and work proficiency,
and compliance with the procedure.
9) Evaluate the program periodically to ensure continued use and
adequacy.
10) Enforce all provisions of the program.

Issued

Sep 25, 1989

Abate by

Jan 1, 1990

Penalty

Initial $480 · Current $360 Reduced

Issued

Sep 25, 1989

Abate by

Jan 1, 1990

Penalty

Initial $560 · Current $420 Reduced

Issued

Sep 25, 1989

Abate by

Jan 1, 1990

Issued

Sep 25, 1989

Abate by

Oct 25, 1989

Penalty

Initial $240 · Current $180 Reduced

Issued

Sep 25, 1989

Abate by

Oct 25, 1989

Issued

Sep 25, 1989

Abate by

Oct 25, 1989

Penalty

Initial $400 · Current $300 Reduced

Issued

Sep 25, 1989

Abate by

Oct 2, 1989

Penalty

Initial $580 · Current $435 Reduced

Issued

Sep 25, 1989

Abate by

Oct 25, 1989

Penalty

Initial $300 · Current $225 Reduced

Issued

Sep 25, 1989

Abate by

Oct 25, 1989

Penalty

Initial $480 · Current $360 Reduced

Issued

Sep 25, 1989

Abate by

Oct 25, 1989

Issued

Sep 25, 1989

Abate by

Jan 1, 1990

Issued

Sep 25, 1989

Abate by

Oct 2, 1989

Issued

Sep 25, 1989

Abate by

Oct 10, 1989

Penalty

Initial $400 · Current $300 Reduced

Issued

Sep 25, 1989

Abate by

Sep 28, 1989

Penalty

Initial $80 · Current $60 Reduced

Issued

Sep 25, 1989

Abate by

Oct 2, 1989