OSHA Inspection: STYRO-TECH LLC

Issued

Nov 17, 2010

Abate by

Jan 14, 2011

Penalty

Initial $2,500 · Current $1,750 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 fire hazard:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and preceding
May 18, 2010, 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 fire hazard.  The employer manufactures expanded
polystyrene foam (styrofoam) in which isopentane is used as the blowing
agent. Process piping used to convey isopentane from the storage tank to
the
extruders was not labeled.
Abatement Note: ASME A13.1-2007 provides a "Scheme for the Identification
of Piping
Systems".  The standard recommends that flammable liquids, such as
isopentane, be
identified with black letters, 1/2" or larger, on a "safety yellow"
background.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Feb 22, 2011

Penalty

Initial $5,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(c)(1) The employer did not develop a written plan of
action regarding the
implementation of the employee participation required by this paragraph:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 the employer did not develop a written plan of action regarding
the
implementation of the employee participation required by the process safety
management (PSM) standard.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Mar 31, 2011

General-duty citation text

29 CFR 1910.119(c)(2) The employer did not consult with employees and their
representatives on the conduct and development of process hazards analyses
and on the
development of the other elements of process safety management in this
standard:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 the employer did not consult with employees on the conduct and
development of the process hazard analyses dated November 14, 2005.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Mar 3, 2011

Penalty

Initial $5,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i) Information pertaining to the technology of the
process did not
include the required elements in paragraphs (A), (B), (D) and (E):
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 the employer did not retain process safety information pertaining
to
the technology of the process in that the employer did not have a block
flow
diagram, information related to process chemistry, safe upper and lower
limits
(for items such as temperatures, pressures, flows or compositions), and an
evaluation of the consequences of deviations.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Apr 7, 2011

General-duty citation text

29 CFR 1910.119(d)(3)(i) Information pertaining to the equipment in the
process did not
include the required elements in paragraphs (A) through (H):
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 the employer did not retain process safety information pertaining
to
the equipment of the process in that the employer did not provide
information
regarding the materials of construction, piping and instrument diagrams,
electrical classification, relief system design and design basis,
ventilation
system design, design codes and standards employed, material and energy
balances for the process, or safety systems (e.g. interlocks, detection, or
suppression systems) for the isopentane process.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Mar 31, 2011

Penalty

Initial $5,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i) The process hazard analysis did not address the
hazards of the
process:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: The employer's
November 14, 2005 PHA did not address the hazard of fire created when
static charge ignites isopentane released at the end of the extruder
during a
process upset such as when polystyrene is broken when pulling it onto
rollers,
or when bubbles are formed in polystyrene at the end of extruder, or when
product becomes clogged at the end of extruder.
(b)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: The employer's
November 14, 2005 PHA did not address the hazards of the process in that
the
PHA does not contain references to process safety information and process
safety information, such as a P&ID was not provided to support the PHA.  In
addition, the PHA contains terminology that prevents clear understanding of
the "what if" questions used and responses provided.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Apr 14, 2011

Penalty

Initial $5,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(e)(4) No member of the team was knowledgeable in the
specific
process
hazard analysis methodology that was used:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: The process hazard
analysis dated November 14, 2005 was not performed by a team which
included at least one member that was knowledgable in the "What If" process
hazard analysis methodology that was used.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Apr 14, 2011

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to promptly
address the
team's findings and recommendations; assure that the recommendations were
resolved in a
timely manner and that the resolution was documented; document what
actions were to be
taken; complete actions as soon as possible; develop a written schedule of
when these actions
were to be completed; communicate the actions to operating, maintenance
and other
employees whose work assignments were in the process and who may have been
affected
by
the recommendations or actions.
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: The employer did
not establish a system to promptly address the PHA team's findings and
recommendations in the November 14, 2005 process hazard analysis.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Feb 16, 2011

Penalty

Initial $5,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(f)(1): The employer shall develop and implement written
operating
procedures that provide clear instructions for safely conducting
activities involved in each
covered process consistent with the process safety information and shall
address at least the
elements in paragraphs (i) through (iv):
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 the employer did not develop and implement written operating
procedures for activities associated with the isopentane process such, but
not
limited to, operation of the extruder and including pulling polystyrene
product
from extruder to roller(s).
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Jan 14, 2011

General-duty citation text

29 CFR 1910.119(f)(3): The operating procedures were not reviewed as often
as necessary to
assure that they reflect current operating practice, including changes
that result from changes
in process chemicals, technology, and equipment, and changes to facilities:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 the Off Loading Procedure had not been updated since February 3,
2006.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Feb 22, 2011

Penalty

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

General-duty citation text

29 CFR 1910.119(g)(1)(i): Training was not provided to each employee
presently
involved in
operating a process, and each employee before being involved in operating
a newly assigned
process, shall be trained in an overview of the process and in the
operating procedures as
specified in paragraph (f) of this section. The training shall include
emphasis on the specific
safety and health hazards, emergency operations including shutdown, and
safe work practices
applicable to the employee's job tasks:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 the employer did not provide training to extruder operators which
included operating procedures and an overview of the process as required in
paragraph (f) of this section.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Feb 22, 2011

General-duty citation text

29 CFR 1910.119(g)(3): The employer did not ascertain that each employee
involved in
operating a process has received and understood the training required by
this
paragraph. The
employer did not prepare a record which contains the identity of the
employee, the date of
training, and the means used to verify that the employee understood the
training:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 the employer did not ascertain that each extruder operator had
received and understood training and did not prepare a record of the
training.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Mar 21, 2011

Penalty

Initial $2,500 · Current $1,750 Reduced

General-duty citation text

29 CFR 1910.119(j)(2):The employer did not establish and implement written
procedures to
maintain the on-going integrity of process equipment:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 mechanical integrity procedures were not established for the
isopentane supply tank, isopentane piping system including valves, relief
valves, LEL sensors and alarms, and pumps.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Apr 15, 2011

Penalty

Initial $5,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): Inspections and tests were not performed on
process equipment to
assure mechanical integrity:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 the employer did not conduct inspection and tests on isopentane
process equipment including, but not limited to, the isopentane supply
tank,
process piping and valves including underground sections of pipe located
between the supply tank and main building, pumps, relief valves, controls,
sensors, and alarms.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Apr 15, 2011

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in
equipment that were
outside acceptable limits before further use or in a safe and timely
manner:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 the employer did not correct deficiencies in equipment associated
with the safe use of isopentane in that the pressure gauge on the
isopentane
supply tank was broken as evidenced by the needle reading less than zero.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Apr 7, 2011

Penalty

Initial $2,000 · Current $1,400 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not establish and implement
written procedures to
manage changes (except for "replacements in kind") to process chemicals,
technology,
equipment, and procedures; and, changes to facilities that affect a
covered process:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 the employer did not establish and implement a written procedure
to
manage changes to process technology, equipment, and procedures such as but
not limited to changing the isopentane supply tank.  A new isopentane
supply
tank was installed in 2007 and no documentation management of change
document was prepared.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Apr 7, 2011

Penalty

Initial $5,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(n): The employer did not establish and implement an
emergency action
plan for the entire plant in accordance with the provisions of 29 CFR
1910.38 and an
emergency response plan in accordance with 29 CFR 1910.120(q)(1):
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 the employer did not establish and implement an emergency response
plan to address spills and releases of isopentane and did not include a
procedure in the emergency action plan for employees to follow to
distinguish
between small and large fires, releases, and/or spills and the
corresponding
employee(s) actions.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Apr 14, 2011

Penalty

Initial $2,000 · Current $1,400 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not certify that they had
evaluated compliance
with the provisions of this section at least every three years to verify
that the procedures and
practices developed under the standard are adequate and are being followed:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 the employer did not certify that they had evaluated compliance
with
the provisions of this section in that the employer did not provide
documentation to show that a compliance audit had ever been performed.
Abatement Note: Abatement certification and documentation are required for
this item (see
enclosed "Sample Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Nov 22, 2010

General-duty citation text

29 CFR 1904.32(a)(2) At the end of each year the employer did not create
an
annual
summary of injuries and illnesses recorded on the OSHA 300 Log:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: For 2006-2009 the
employer did not create an annual summary of injuries and illnesses (300-A)
recorded on the OSHA 300 Logs.
Abatement Note: Abatement certification is not required for this item (see
enclosed "Sample
Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Jan 14, 2011

General-duty citation text

29 CFR 1910.95(i)(3) Employees were not given the opportunity to select
their hearing
protectors from a variety of suitable hearing protectors provided by the
employer:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 employees were not given the opportunity to select their hearing
protection from a variety of suitable hearing protectors provided by the
employer.  This condition prevented employees from selected hearing
protectors that offered sufficient attenuation and comfort as needed to
protect
their hearing.
Abatement Note: Abatement certification is required for this item (see
enclosed "Sample
Abatement Certification Letter").

Issued

Nov 17, 2010

Abate by

Jan 14, 2011

General-duty citation text

29 CFR 1910.1200(f)(5)(i): The employer did not ensure that each container
of hazardous
chemicals in the workplace was labeled, tagged or marked with the identity
of the hazardous
chemical(s) therein:
(a)Styro-Tech LLC at 5005 Lima St., Denver, CO 80239: On and before May
18, 2010 the employer did not ensure each container of hazardous chemicals
was labeled or marked to indicate the contents in that a can of "wax acid"
was
found near the extruder with no label. This condition exposed employees in
extrusion area to skin hazards.
Abatement Note: The minimum information required on a chemical label is
the:
(1)Identity of the hazardous chemical(s); and
(2)Appropriate hazard warnings.
Abatement Note: Abatement certification is required for this item (See
enclosed "Sample
Abatement-Certification Letter").