OSHA Inspection: BENJAMIN MOORE & CO.

Issued

Jan 18, 2011

Abate by

Apr 1, 2011

Penalty

Initial $5,000

General-duty citation text

29 CFR 1910.119(d)(3)(ii):  The employer did not document that the
equipment in the process
complied with recognized and generally accepted good engineering practices:
(a)Resin Process Area, 7k reactor and associated equipment:  Piping &
Instrumentation Diagrams (P&IDs) were not complete, in that process
equipment
and instruments, including but not limited to:  valves, pumps, pipes, logic
controllers, and instruments, were not properly identified on the P&IDs,
on or
prior to 8/6/10.
Pursuant to 29 CFR 1903.19(c), the employer must provide certification and
documentation to OSHA that this violation has been abated within 10
calendar days of the "Date by which Violation Must be Abated".

Issued

Jan 18, 2011

Abate by

May 1, 2011

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(e)(3)(vi):  The process hazard analysis did not address
human factors:
(a)Resin Process Area, 7k and 10k units, on or prior to 8/6/10:  The
process hazard
analysis did not address human factors, including, but not limited to:
-Operator failure to follow the established shift change procedure and
communicate safety-critical information to the incoming shift.
-Communication issues between control room operators and third person
on resin room floor; no radios or other effective means of communication
was utilized.
-Excessive or redundant control panel alarms, resulting in operator failure
to notice or respond to a critical alarm.
-Operator inattentiveness and/or judgement errors created by fatigue issues
associated with 12 hour work shift(s).
-Operator failure to abort actions to control an escalating emergency
situation (i.e. runaway reaction) and instead evacuate the plant.
-Operator failure to follow specific, safety critical procedural steps
outlined
in 7k and 10k reactor operations manuals.
Pursuant to 29 CFR 1903.19(c), the employer must provide certification and
documentation to OSHA that this violation has been abated within 10
calendar days of the "Date by which Violation Must be Abated".

Issued

Jan 18, 2011

Abate by

Feb 22, 2011

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(f)(1)(i)(E):  The employer's written operating procedures
covering the steps
for each operating phase did not address emergency operations:
(a)Resin process, 7k and 10k units:  Written operating procedures did not
clearly
address or define situations where emergency shutdown and evacuation of the
plant was appropriate, including, but not limited to:  runaway reaction,
fire, large
vapor release, etc., on or prior to 8/6/10.
Pursuant to 29 CFR 1903.19(c), the employer must provide certification to
OSHA that this violation has been abated within 10 calendar days of the
"Date by which Violation Must be Abated".