OSHA Inspection: INEOS USA LLC

Issued

Jan 13, 2011

Abate by

Dec 15, 2011

Penalty

Initial $2,500 · Current $2,500

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 dust explosion, deflagration, or other fire
hazard from process
equipment that was not protected by proper venting, inerting, or
containment, or suppression
systems:
(a) INEOS USA LLC, 1900 Fort Amanda Road, Lima, Ohio:  On or about July
22, 2010, the employer did not ensure that process equipment in the Barex
processing
unit was protected with explosion venting, inerting or containment, or
suppression
systems, to include but not limited to, silo dust collectors and storage
silos / bins.
Analytical results revealed that the dust in the unit was explosive and a
Class II
material.
Among other methods, a feasible abatement methods to correct this hazard
is: perform a
process hazard analysis (PHA) of the processes and the facility per the
intent of NFPA 654-
2006 section 4.2 - standard for the Prevention of Fire and Dust Explosions
from the
Manufacturing, Processing and Handling of Combustible Particulate Solids;
install
engineering controls such as deflagration venting in accordance with the
requirements of
NFPA 654 section 7.1.2.1(2);  install isolation devices to prevent
deflagration propagation
between pieces of equipment connected by ductwork in accordance with NFPA
654 section
7.1.4.1;  and install isolation devices to prevent deflagration
propagation upstream into the
work areas in accordance with NFPA 654 section 7.1.5.1.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation (
using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition,
documentation demonstrating that abatement is complete must be included
with your
certification.  This documentation may include, but is not limited to,
evidence of the
purchase or repair of the equipment, photographic or video evidence, or
written records.

Issued

Jan 13, 2011

Abate by

Feb 15, 2011

Penalty

Initial $2,500 · Current $2,500

General-duty citation text

29 CFR 1910.119(e)(3)(i):  The process hazard analysis did not address the
hazards of the
process:
(a)INEOS USA LLC, 1900 Fort Amanda Road, Lima, Ohio:  On or about July
22, 2010, the employer did not ensure that the process hazard analysis
(PHA)
for the
Barex unit addressed the hazards associated with combustible dust. The
resin dust was
determined to be explosive and a Class II dust.  Process units handling
resin dust
were not equipped with deflagration controls, such as but not limited to,
explosion
venting, deflagration isolation, spark detection, and heat detection.
Employees were
at risk of serious injuries from exposure to the hazards associated with
fires and
explosions from the dust.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation (
using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition,
documentation demonstrating that abatement is complete must be included
with your
certification.  This documentation may include, but is not limited to,
evidence of the
purchase or repair of the equipment, photographic or video evidence, or
written records.

Issued

Jan 13, 2011

Abate by

Feb 15, 2011

Penalty

Initial $2,500

General-duty citation text

29 CFR 1910.119(e)(3)(v):  The process hazard analysis did not address
facility siting:
(a)INEOS USA LLC, 1900 Fort Amanda Road, Lima, Ohio:  On or about July
22, 2010, the employer did not ensure that the facility siting process
hazard analsys
(PHA) for the Barex unit addressed the hazards associated with not
maintaining a
pressurized control room.  Failure to maintain the control room, which
contained
equipment not rated for a hazardous location, under positive pressure
could allow
flammable vapors to enter the room and be ignited.  Employees were exposed
to
serious injury from fire and explosion hazards.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation (
using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition,
documentation demonstrating that abatement is complete must be included
with your
certification.  This documentation may include, but is not limited to,
evidence of the
purchase or repair of the equipment, photographic or video evidence, or
written records.

Issued

Jan 13, 2011

Abate by

Feb 15, 2011

Penalty

Initial $55,000 · Current $55,000

General-duty citation text

29 CFR 1910.119(l)(1):   The employer did not establish and implement
written procedures
to manage changes to process chemicals, technology, equipment, and
procedures; and
changes to facilities that affect a covered process.
(a)INEOS USA LLC, 1900 Fort Amanda Road, Lima, Ohio:  On or about July
22, 2010, the employer did not ensure that a management of change procedure
(MOC) was implemented when the lights in the Barex stairwell were
replaced.  The
stairwell in the Barex building was classified as a Class I, division 2
environment and
the replacement lights were not rated for a hazardous environment.  Using
electrical
equipment not rated for hazardous environments exposed employees to fire
and
explosion hazards.
(b)INEOS USA LLC, 1900 Fort Amanda Road, Lima, Ohio:  On or about July
22, 2010, the employer did not ensure that a management of change procedure
(MOC) was implemented when personnel determined that the lighting fixtures
installed in the Barex process building stairwell were not approved for a
Class I
environment and implemented corrective actions. Using the MOC system, which
includes a hazard analysis review, would likely have addressed potential
hazards
associated with removing the lights from service, such as but not limited
to, low
lighting conditions in a stairwell used as an emergency exit.
(c)INEOS USA LLC, 1900 Fort Amanda Road, Lima, Ohio:  On or about July
22, 2010, the employer did not ensure that a management of change procedure
(MOC) was implemented when the HVAC unit for the Barex control room failed
and
the room was not maintained with a positive pressure environment.  The
equipment in
the control room was not rated for a hazardous environment and exposed
employees
to fire and explosion hazards.
In accordance with 29 CFR 1903.19(d), abatement certification is required
for this violation (
using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition,
documentation demonstrating that abatement is complete must be included
with your
certification.  This documentation may include, but is not limited to,
evidence
of the
purchase or repair of the equipment, photographic or video evidence, or
written records.