OSHA Inspection: EUCLID CHEMICAL CO.

Issued

Oct 16, 1998

Abate by

Nov 18, 1998

Penalty

Initial $3,500 · Current $2,450 Reduced

Hazardous substances 03720921T196

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 potential chemical burns and explosion hazards:
On August 11, 1998, Vat B of the Epoxy Packaging (Liquid Fill) machine
overfilled, causing
the lid to fly off and liquid epoxy to release onto the operator and
elsewhere.  The epoxy
contains ingredients that cause eye damage, skin burns and allergic
sensitization.
Vats A and B are reservoir containers made of 18 gauge stainless steel, 18
inches in diameter,
holding approximately 11 gallons; in this application they are used
exclusively for epoxy
products (Flash Points over 200 degrees F.), not for flammable liquids.
Vats A and B are
pressure vessels in that they are designed for operation at pressures
greater than 15 psi;
specifically the vessel can sustain continuous pressure of 50 psi, the
pressure relief valve does
not actuate until at least 25 psi, and the manufacturer's instruction
manual states that they "can
be pressurized up to 18 psi". The vessel was not in accordance with the
ASME Boiler and
Pressure Vessel Code, Section VIII, 1995 (with 1997 Addenda).
a) The lids of the vats were not constructed in accordance with ASME
Boiler and Pressure
Vessel Code, Section VIII, UG-35(b), "Quick-Actuating Closure
(Quick-Opening Closures)",
which states as follows:
Closures other than the multibolted type designed to provide access to the
contents space of a pressure vessel shall have a locking mechanism or
locking
device so designed that failure of any one locking element or component in
the
locking mechanism cannot result in the failure of all other locking
elements and
the release of the closure.
b) The pressure relief devices were not in accordance with ASME Boiler and
Vessel Code,
Section VIII, UG-125(c), "Pressure Relief Devices - General", which states
as follows:
All pressure vessels other than unfired steam vessels shall be protected
by a
pressure relief device that shall prevent the pressure from rising more
than 10
or 3 psi, whichever is greater, above the maximum allowable working
pressure.
c) The seal band was not tightened in accordance with the manufacturer's
instructions which
state as follows :
Tighten nuts on pressure tank seal band until coil springs touch each
other.
d) The float system was not inspected in accordance with the
manufacturer's instructions which
state as follows:
Holding the tank lid level, or float system cover, manually lift each of
the floats
and observe the inlet valves open and close appropriately when the upper
ball is
lifted.e) The pressure relief valve was not inspected in accordance with
the manufacturer's instructions
which state as follows:
Open the pressure relief valve at least weekly to make sure it is not
blocked,
closed or obstructed or otherwise disabled.
f) The reservoir vats were not marked in accordance with ASME Boiler and
Pressure Vessel
Code, Section VIII, UG-116(a) and (b), "Required Marking".
g) The pressure relief valves were not marked in accordance with ASME
Boiler and Pressure
Vessel Code., Section VIII, UG-129(a), "Marking - Safety, Safety Relief,
Relief, Liquid
Pressure Relief, and Pilot Operated Pressure Relief Valves".
Note: Feasible and acceptable abatement methods include but are not
limited to:
1) Retrain all operators and supervisors on the correct method of assuring
adequate tightness of
the seal band;
2) Place labels on both sides of the vats with instructions on proper
tightening;
3) Add audible fill level and pressure level alarms to Vats A and B;
4) Retrain the employees on inspection, cleaning, the significance of the
displays on the control
panel, and procedures to follow if the alarms are activated;
5) Require the operators to complete a thorough inspection of the
equipment at the start of each
shift or before its use, including but not limited to the cleanliness and
proper functioning of the
floats and pressure gauges, preferably utilizing a written checklist to
provide a record of the
inspection;
6) Require the supervisors to check the equipment on a random basis,
including but not limited
to cleanliness, the tightness of the seal band, and proper functioning of
the float and pressure
relief valve;
7) Enforce the inspection and cleaning requirements, through disciplinary
measures if necessary;
8) Train operators and supervisors to conduct complete incident
investigation for accident and
"near miss" incidents, including recommendations for prevention;
9) Implement recommended improvements wherever practical.

Issued

Oct 16, 1998

Abate by

Oct 21, 1998

Penalty

Initial $1,100 · Current $770 Reduced

Hazardous substances 25902270

Issued

Oct 16, 1998

Abate by

Oct 24, 1998

Penalty

Initial $1,100 · Current $770 Reduced

Hazardous substances 25902270

Issued

Oct 16, 1998

Abate by

Oct 22, 1998

Penalty

Initial $1,375 · Current $962 Reduced

Hazardous substances 2150

Issued

Oct 16, 1998

Abate by

Oct 24, 1998

Hazardous substances 03720921T196

Issued

Oct 16, 1998

Abate by

Dec 31, 1998

Penalty

Initial $1,375

Hazardous substances 0921T196