OSHA Inspection: UNITED ERIE, INC.

Issued

Aug 27, 1991

Abate by

May 20, 1992

Penalty

Initial $1,125 · Current $1,000 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 severe burns, concussions, and multiple traumatic injuries
from fire and explosion due to overpressurization of mix tanks caused
by runaway reactions in the vessels during the manufacturing of
finished goods, on or about June 11, 1991:
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 that will include, but not
necessarily be limited to, the following provisions:
a.  Chemical Process Hazard Review: Conduct a chemical process
system safety hazard review that will identify process de-
ficiencies and upsets plus estimate their frequency and prob-
able consequences.  Operating parameters, procedures and/or
process control instrumentation determined by this review to
be critical for the safe processing of finished goods shall be
designed and construced for either redundancy or back-up to
assure maximum feasible safety to employees.  This review shall
be of a type generally recognized in chemical processing
industires (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 consequences of excessive temperatures
and pressures or variations in material controls.
(ii)  Preparation and review of a piping and
instrumentation diagram (P&ID) to assure that controls
and instrumentation will detect unusual conditions
and that the system will automatically shut down or
can be safely shut down in the event of operator or
equipment error.
(iii) Review of raw material MSDSs, product bulletins,
technical and scientific literature, considering fire,
explosion, health, stability and reactivity character-
istics including handling, storage, emergency
procedures and special precautions.
(iv) Review of the chemical reaction process
considering potential problems arising from abnormal
temperature rises, pressure rises and rates of
reaction.
(v) Review of operating equipment used in the
processing of finished goods considering the adequacy
of design and fabrication; effects of corrosion,
erosion and metal fatigue, potential for exceeding
design limitations; equipment leaks and spills;
equipment malfunctions and failures; plus maintenance,
repair and replacement programs.
(vi) Review of operating design and potential for
operational errors considering detailed operating
descriptions and Standard Operating Procedures;
accuracy and readibility of control instrumentation
and operator training in process chemistry, hazards
and operational procedures.
b. Standard Operating Procedures
(i) Establish written detailed descriptions and
Standard Operating Procedures for the manufacture
of finished goods in mix tanks to assure safe start-up
and processing within controllable limits and to
provide for safe shutdown of equipment in the event
of abnormal conditions.  These procedures shall
address, but not necessarily be limited to the
following:
(1) Start-Up procedures for mix tank batch
process that will include checks to ensure
process equipment and controls are functioning
properly emergency devices are in proper working
order and the mix tank is clean and/or otherwise
free of possible hazardous contaminants before
use.
(2) Normal operating procedures for the mix
tank batch process that will include a defined
sequence of operating steps emphasizing those
considered to be critical for process safety
plus requirements for operator personal
protective equipment and practices for safe
operation.
(3) Emergency shutdown procedures for the mix
tank batch process that will define abnormal
operating conditions and specify sequential
steps for safe shutdown of equipment or timely
evacuation of operating personnel plus proper
removal techniques of any residual flammable,
unstable, corrosive or toxic materials.
(ii) Instruct and train all affected managment,
supervisory and operations personnel in these Standard
Operating Procedures.
(iii) Periodically evaluate these Standard Operating
Procedures to determine their continued adequacy.
Any changes made to these procedures should be
thoroughly documented and reviewed.   Personnel shall
be trained in any revisions along with the reasons
for them before they are implemented.
c. Operational and Safety Controls:
Install the following operational and/or safety controls for
the manufacture of finished goods in batch mix tanks:
(i) An effective display indicating when cooling
systems are being applied to the mix tanks.
(ii) An effective display indicating whether or not
cooling systems are being applied.
(iii) Fail-safe agitator and cooling system failure
alarms or warning devices for mix tanks and their
condensors.
(iv) Fail-safe automatic high temperature shutoff
devices on mix tank.
(v) Suitable batch mixture temperature monitors
connected to fail-safe high temperature alarms
protected by a secured enclosure or other means to
prevent them from being disengaged or turned off by
operators during operations.
(vi) An emergency switch at the normal exit door and
at pumps so arranged to shut down all pumps
transferring solvents from storage to points of use
in the event of fire or other emergency.
d. Adequate Emergency Relief Devices:
Install emergency pressure-relieving devices on batch mix
tanks sufficiently rated to carry off the maximum generated
or supplied quantity of liquid and/or vapor based on the
physical phenomenon of two phase flow while permitting no
more than a ten percent rise above the maximum allowable
working pressure within the vessel when these devices are
blowing.

Issued

Aug 27, 1991

Abate by

Sep 20, 1991

Penalty

Initial $675 · Current $500 Reduced

Issued

Aug 27, 1991

Abate by

Aug 30, 1991

Penalty

Initial $2,250 · Current $2,000 Reduced

Issued

Aug 27, 1991

Abate by

Dec 25, 1991