OSHA Inspection: UCT SPECIALTIES, LLC

Issued

Sep 30, 1994

Abate by

Nov 18, 1994

Penalty

Initial $3,000 · Current $2,500 Reduced

Hazardous substances 2280

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 fire and explosion hazards during the production of
phenethyltrichlorosilane in the
100 gallon still on June 21, 1994.  The following conditions contributed
to the existence of these
hazards:
a)  The operating procedure for the phenethyltrichlorosilane (p0110)
product did not
provide clear instructions for safely conducting all activities involved
in each step of the
process.
b)  Employees were not properly trained in standard operating procedures
and were not
adequately trained in the safe handling, processing and storage of
flammable liquids.
c)  The mechanical integrity and compatibility of all process equipment
was not initially
or periodically inspected as necessary by the hazards of the process or
frequency of use.
d)  A complete hazard and operability study of the p0110 process was not
conducted to
determine likely hazards related to equipment, procedures and chemicals
used in the
process.
ABATEMENT NOTE:
Among other methods, one feasible and acceptable abatement method to
correct this hazard is
to:
1.  Implementation of written Standard Operating Procedures for each
chemical
production and processing operation which contain, at least, the following
(Instance (a)):
a)General description of the process.
b)Properties of the materials involved.
c)Description of the equipment including process equipment,
instrumentation, and protective equipment.
d)Startup and shutdown procedures, including checkout procedures.
e)Normal operating procedures.
f)Safety considerations relative to fire, explosion, accidents, and health.
g)Safe operating limits.
h)Precautions and actions to be avoided.
i)What constitutes an emergency?
j)Emergency procedures.
2.  Implementation of training program for all chemical operators to
include the
following  (Instance (b)):
a)  Process goals economics, constraints and priorities
b)  Process flow diagramc)Unit operations
d)Process reactions, thermal effects
e)Control systems
f)Process materials quality, yields
g)Process effluent and wastes
h)Plant equipment
i)Instrumentation
j)Equipment identification
k)Equipment manipulation
l)Operating procedures
m)Equipment maintenance and cleaning
n)Use of tools
o)Permit Systems
p)Equipment failure, services failure
q)Fault administration
r)Emergency procedures
s)Fire fighting
t)Malpractice
u)Communication, record-keeping, reporting
3.  Implementation of a program to inspect all process equipment and
containers before
initial use and thereafter on a periodic basis to included at least the
following  (Instance
(c)):
a)Reliability engineering
b)Materials of construction
c)Fabrication and inspection procedures
d)Installation procedures
c)Preventive Maintenance
d)Process hardware and systems inspections and testing
e)Maintenance procedures
f)Alarm and instrument management
g)Decommissioning and demolition procedures
4)  Implementation of a program to evaluate and identify process hazards
using
procedures which have been recognized and used throughout the chemical
industry.
These procedures would include the gathering of process safety information
and a formal
evaluation of that information (Instance (d)).

Issued

Sep 30, 1994

Abate by

Nov 2, 1994

Penalty

Initial $3,000 · Current $2,500 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 the hazards of collapsing walls and roof do to a chemical
explosion while working
at a light assembly operation.:
a)  Employees working in an assembly area next to the Silane Kettle Room
where class
IA flammable and unstable chemicals were processed were not protected or
separated
from the hazards of this operation by explosion resistant construction.
Among other methods, one feasible and acceptable abatement method to
correct this hazard is
to:
1)Install exposing resistant walls between the hazardous operations area
and the
light assembly area.
2)Move assembly operations away from chemical processing areas.

Issued

Sep 30, 1994

Abate by

Oct 7, 1994

Penalty

Initial $3,000 · Current $1,800 Reduced

Issued

Sep 30, 1994

Abate by

Oct 7, 1994

Penalty

Initial $7,000 · Current $4,200 Reduced

Issued

Sep 30, 1994

Abate by

Nov 2, 1994

Penalty

Initial $3,000 · Current $1,800 Reduced

Issued

Sep 30, 1994

Abate by

Nov 2, 1994

Penalty

Initial $3,000 · Current $1,800 Reduced

Issued

Sep 30, 1994

Abate by

Oct 13, 1994

Penalty

Initial $3,000 · Current $1,800 Reduced

Issued

Sep 30, 1994

Abate by

Oct 7, 1994

Issued

Sep 30, 1994

Abate by

Oct 13, 1994

Penalty

Initial $3,000 · Current $1,800 Reduced

Issued

Sep 30, 1994

Abate by

Oct 7, 1994

Issued

Sep 30, 1994

Abate by

Nov 2, 1994

Penalty

Initial $900 · Current $540 Reduced

Issued

Sep 30, 1994

Abate by

Nov 2, 1994

Issued

Sep 30, 1994

Abate by

Nov 2, 1994

Issued

Sep 30, 1994

Abate by

Oct 18, 1994

Issued

Sep 30, 1994

Abate by

Oct 13, 1994

Issued

Sep 30, 1994

Abate by

Nov 2, 1994

Penalty

Initial $1,200 · Current $720 Reduced

Issued

Sep 30, 1994

Abate by

Oct 7, 1994

Penalty

Initial $7,000 · Current $3,680 Reduced

Issued

Sep 30, 1994

Abate by

Oct 7, 1994

Penalty

Initial $600 · Current $360 Reduced

Issued

Sep 30, 1994

Abate by

Oct 13, 1994

Issued

Sep 30, 1994

Abate by

Oct 13, 1994