OSHA Inspection: MALLINCKRODT INC.

Issued

Jan 20, 1999

Abate by

Mar 9, 1999

Penalty

Initial $5,000 · Current $3,750 Reduced

Hazardous substances 1460

General-duty citation text

29 USC 654: Section 5(a)(1) of the Occupational Safety and Health Act of
1970:  The employer
did not furnish employmnent 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:
a/  Employees changed out 100# cylinders of hydrogen fluoride connecting
the cylinders to a
production process without being protected from the potential of pressure
release of hydrogen
fluoride during the line breaking procedure.
AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT
METHOD TO CORRECT THIS HAZARD IS....the placement of a pressure regulator
on line
with pressure relief control venting to the scrubbers or other safe
location.  The system would
be so constructed that any excessive pressure which could damage or
threaten the safety of the
process and the employees would be vented to a safe location prior to the
pressure
reaching the
process.
A second feasible and acceptable abatement method would be to place valves
and pressure gauge
on line such that the pressure on the cylinder  would be known by opening
the first valve
providing pressure to reach the pressure gauge so that the pressure on the
system could be
determine before the valve connecting the cylinder to the process was
opened.  A method of
releasing the pressure if necessary would be provided through a pressure
relief valve vented to
the scrubber or other safe location.
With any abatement, the abatement must include the development and
implementation of a
written safe work practice describing the step by step process of the
steps to take to bring to
change out a cylinder of HF from the process. and the steps to be taken if
excessive pressure
is released from the cylinder during that cylinder change.
Abatement certification and abatement documentation is required for this
violation.  The
documentation should include written verification of abatement, applicable
measurements of
monitoring results, and photographs or videos which you believe will be
helpful.  The abatement
certification sheet is enclosed with this citation(s).