OSHA Inspection: ADVANCED ENVIRONMENTAL RECYCLING COMPANY, L.L.C.

Issued

Jul 6, 2000

Abate by

Aug 31, 2000

Penalty

Initial $2,500 · Current $1,500 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 a potential fire, explosion and pressurization hazard from
the heating of
materials incompatible with the safe operation of a Mercury Retort Oven:
a) Advanced Environmental Recycling Company, L.L.C. employee(s) were
exposed to
the hazards of fire, explosion and pressurization of the No. 1 Mercury
Retort Unit, when
material(s) incompatible with the safe operation of the oven were allowed
to be loaded
into trays (boats) and processed (heated for a period of time) in the No.
1 Retort oven,
when on March 14, 2000, a fire occurred during the early morning hours and
subsequently pressurization of the Retort oven occurred later in the day,
which resulted
in the Retort's door being blown open and off its' hinge, and struck an
employee who
was engaged in a cleaning activity directly in front of the unit's door.
Feasible means to abate this hazard includes but is not limited to the
following:
1) Re-evaluate all of the safety features of the Retort unit(s), with
specific attention being
focussed on the possible use and placement of pressure relief device(s).
2) Develop and institute detailed procedures for identification and
classification of
incoming materials to be "retorted", so as to ensure only compatible
materials are
processed in this operation.  This process must include rigorous steps to
inspect the
incoming shipments of materials and the "fingerprinting" of the waste and
its origination
by direct verification of the information completed on the Bill of Lading
or Shipping
Manifest.  In cases involving any discrepancies, steps need to be taken
and documented
to contact the generator, supplier or shipper, collection of samples for
analysis, or
rejection of the shipment.
3) A method for clear and concise means of communication of Retort
process(es) needs
to be developed for all process runs, especially those that exceed the
loading shifts work
duration, so that all operators, shift supervisors, production/operations
managers and
process engineer(s) are aware of the steps taken in the processing and
operations of the
Retort units, specifically including those that are out of the "normal"
operating
parameters.  In situations which are out of the "norm", an immediate chain
of contact
needs to be developed and utilized for prompt process decisions.
4) Thorough re-training must be conducted to ensure that workers
performing any task
with the Mercury Retort ovens are knowledgeable of the process procedures,
process
control equipment and devices, normal operating conditions and any
potential upset or
emergency conditions.  The performance of a process hazard analysis, such
as
but not
limited to those hazard analysis as, the What-if Analysis, the Checklist
Analysis, the
What-if/Checklist Analysis, the Fault Tree Analysis, and/or the Failure
Mode Effects
Analysis may aid not only as a tool for employee training, but also as a
means for
possible identification of other potential upset conditions.
Abatement certification and documentation required within 10 days after
abatement date.  The
certification shall include a statement that abatement is complete, the
date and method of
abatement, and state that employees and their representatives were
informed of this abatement.
Abatement documentation shall include documents demonstrating that
abatement is complete,
such as evidence of the purchase or repair of equipment, photographic or
video evidence of
abatement or other written records.

Issued

Jul 6, 2000

Abate by

Aug 31, 2000