OSHA Inspection: HOWARD FERTILIZER & CHEMICAL COMPANY, INC.

Issued

Jul 5, 2005

Abate by

Jul 22, 2005

Penalty

Initial $3,500 · Current $3,093 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 hazard of being struck by fragments of metal
drum due to
over-pressurization:
a. At the Ronstar process, heating of chemicals inside steel drums was
performed using "turkey heaters".  The direct heat caused possible
decomposition of the product and/or off-gassing, subsequently over
pressurizing the steel drum which contained the product. The following
measures were not taken to prevent the possibility of an explosion:
1. Employees were not provided training and education relating
to the heating process and the possible physical and chemical
changes taking place during the process.  Also, employees were
not trained in the hazards associated with heating a product that
may expand during phase changes from solid to a liquid and
hazards associated with the changes.
2. The employer did not develop written procedures that would
outline the heating process and provide employees with
instructions and the proper steps to take in order to safely heat
the product.  A hazard analysis was not conducted as to what
hazardous conditions are created by having direct heat through a
flame on the product (pendimethalin) which decomposes at 471
degrees F.
3. The employer did not take any steps to assure that the drums
were provided with means of relieving the pressure in the event
of over pressurization. The drums were not retro-fitted with
devices such as a relief valve or a rupture disk, or have the
bongs designed in a manner that it would prevent them from
being screwed back into the drum causing decomposition
products to pressurize the drum.
Among other methods feasible and acceptable methods to correct this hazard
is
to do the following:
1. Develop and implement written operating procedures that
would prescribe safe methods of heating the steel drums
containing the products and assure that the products are not
heated past their decomposition temperatures.  The procedures
must also prevent the steel drums from being heated while
having the bongs in place and in the closed position,
consequently causing the drum to maintain pressure while being
heated.2. Develop and maintain a temperature log for the drums being
heated to assure that heating does not exceed safe temperatures.
This log must also assure that the temperature of the heated
drums is maintained within the safe phase change range and not
within the dangerous decomposition temperature range.
3. Train employees in the procedures developed and the physical
and chemical properties of the products as well as the physical
changes and possible chemical changes taking place during the
heating process.
4. Evaluate and establish a safe heating process that would
assure that temperatures applied do not cause decomposition or
any other off-gassing which could introduce a hazard to
employees.  Also assure that the heating process is performed
only with drums which have been retro-fitted with equipment
such as relief valves or rupture disks, or by redesigning the
bongs so they cannot be in the closed position causing a drum to
be sealed and build up pressure while being heated.

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Initial $3,500 · Current $3,093 Reduced

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Issued

Jul 5, 2005

Abate by

Aug 30, 2005

Penalty

Initial $3,500 · Current $3,093 Reduced

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Initial $1,050 · Current $888 Reduced

Issued

Jul 5, 2005

Abate by

Aug 30, 2005

Penalty

Initial $1,750 · Current $1,518 Reduced

Issued

Jul 5, 2005

Abate by

Jul 15, 2005

Penalty

Initial $1,750 · Current $1,518 Reduced

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Initial $1,050 · Current $888 Reduced

Issued

Jul 5, 2005

Abate by

Aug 7, 2005

Penalty

Initial $3,500 · Current $3,093 Reduced

Issued

Jul 5, 2005

Abate by

Jul 15, 2005

Penalty

Initial $1,050 · Current $888 Reduced

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Initial $1,050 · Current $888 Reduced

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Initial $1,050 · Current $888 Reduced

Issued

Jul 5, 2005

Abate by

Jul 15, 2005

Penalty

Initial $1,050 · Current $888 Reduced

Issued

Jul 5, 2005

Abate by

Jul 15, 2005

Penalty

Initial $1,750 · Current $1,518 Reduced

Issued

Jul 5, 2005

Abate by

Aug 30, 2005

Penalty

Initial $1,750 · Current $1,518 Reduced

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Initial $1,750 · Current $1,518 Reduced

Issued

Jul 5, 2005

Abate by

Jul 15, 2005

Penalty

Initial $1,050 · Current $888 Reduced

Issued

Jul 5, 2005

Abate by

Jul 15, 2005

Penalty

Initial $1,750 · Current $1,518 Reduced

Issued

Jul 5, 2005

Abate by

Jul 15, 2005

Issued

Jul 5, 2005

Abate by

Jul 15, 2005

Penalty

Initial $1,750 · Current $1,518 Reduced

Issued

Jul 5, 2005

Abate by

Jul 15, 2005

Issued

Jul 5, 2005

Abate by

Jul 15, 2005

Penalty

Initial $1,750 · Current $1,518 Reduced

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Initial $1,050 · Current $888 Reduced

Issued

Jul 5, 2005

Abate by

Jul 15, 2005

Penalty

Initial $1,050 · Current $888 Reduced

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Initial $1,750 · Current $1,518 Reduced

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Initial $3,500 · Current $3,093 Reduced

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Initial $1,050 · Current $888 Reduced

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Initial $1,050 · Current $888 Reduced

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Initial $1,750 · Current $1,518 Reduced

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Initial $1,750 · Current $1,518 Reduced

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Initial $1,050 · Current $888 Reduced

Issued

Jul 5, 2005

Abate by

Jul 15, 2005

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Initial $1,750 · Current $1,518 Reduced

Issued

Jul 5, 2005

Abate by

Jul 15, 2005

Penalty

Initial $1,750 · Current $1,518 Reduced

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Penalty

Current $3,093

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Issued

Jul 5, 2005

Abate by

Jul 11, 2005

Issued

Jul 5, 2005

Abate by

Jul 22, 2005

Penalty

Current $3,343

Issued

Jul 5, 2005

Abate by

Jul 22, 2005

Issued

Jul 5, 2005

Abate by

Jul 22, 2005

Issued

Jul 5, 2005

Abate by

Jul 22, 2005