OSHA Inspection: LOVELAND PRODUCTS, INC.

Issued

2012-01-23 00:00:00

Abate by

2012-03-02 00:00:00

Penalty

Initial $4000.00 · Current $2000.00 Reduced

General-duty citation text

29 CFR 1910.22(a)(2):  Floor(s) of workroom(s) were not maintained in a
clean and, so far
as possible, a dry condition.
Quonset Hut Storage Area:  The floor in the hut is not maintained in a
clean
and dry
condition.  The roof of the structure has failed and after a rain shower,
the water
accumulates on the floors and has also damaged product stored in the
structure.  The
damaged product (boxes holding plastic containers) has fallen over due to
the water damage
onto the floors and spilled the product.
Abatement certification is required for this violation. The abatement
certification sheet is
enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-10 00:00:00

Penalty

Initial $5000.00 · Current $2500.00 Reduced

General-duty citation text

29 CFR 1910.22(d)(1):  On every building or other structure, or part
thereof, used for
mercantile, business, industrial or storage purposes, the loads approved
by the building
official were not marked on plates of approved design and securely affixed
to the building:
At the following locations, the floor loading has not been posted to show
the floor capacity
of the structure.  Without this knowledge it is possible to overload the
floor to the point of
failure:
a. Office Area, 2nd level office and storage.
b.Air Compressor area, 2nd level storage.
Abatement certification is required for this violation. The abatement
certification sheet is
enclosed with the citations.ion

Issued

2012-01-23 00:00:00

Abate by

2012-02-24 00:00:00

Penalty

Initial $7000.00 · Current $3500.00 Reduced

General-duty citation text

29 CFR 1910.38(c)(2):  The employer failed to develop procedures for
emergency evacuation
which included the type of evacuation and exit route assignments:
Throughout the Facility:  The employer has not developed any type of exit
routes for the
employees to follow in the event of an evacuation.  The facility uses
ammonia as part of
their production and a release could harm any employee that does not
evacuate to a safe,
predetermined area.  The evacuation plan should include a method for
determining the safe
route and rally point.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful. The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-24 00:00:00

General-duty citation text

29 CFR 1910.38(c)(4):  The employer failed to develop procedures for
emergency evacuation
which include procedures to account for all employees after an evacuation:
Throughout the Facility:  The employer has not developed any type of
system to account for
the employees in the event of an evacuation.  This would include a method
to track the daily
employee counts so that there could be an accurate count at any evacuation
location.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful. The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-05-31 00:00:00

General-duty citation text

29 CFR 1910.38(d):  The employer failed to have and maintain an employee
alarm system.
The alarm system must use a distinctive signal for each purpose:
Throughout the Facility:  The employer has not installed any form of alarm
system which
would notify the employees of an ammonia release.  The reactor area does
have an ammonia
detector with a local alarm, but that does not provide for notification to
the rest of the
facility.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful. The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-24 00:00:00

Penalty

Initial $7000.00 · Current $4500.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B):  Process safety information pertaining to the
equipment in the
process did not include accurate Piping and Instrumentation Diagrams
(P&ID):
Throughout the Facility:  The Piping and Instrumentation Diagram developed
for the system
did not include all of the components of the system.  Safety Relief Valves
(SRV)located on
the North and South Reactors were not included in the diagram.  The P&ID
also omitted the
SRV release locations.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful. The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-24 00:00:00

Penalty

Initial $7000.00 · Current $7000.00

General-duty citation text

29 CFR 1910.119(e)(3)(i):  The process hazard analysis did not address the
hazard of the
process:
Throughout the Facility:  The Process Hazard Analysis (PHA) which was
performed in 2009
failed to address the hazards of the process.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful. The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-24 00:00:00

Penalty

Initial $7000.00

General-duty citation text

29 CFR 1910.119(e)(3)(v):  The process hazard analysis did not address
facility siting:
Throughout the Facility:  The Process Hazard Analysis (PHA) which was
performed in 2009
failed to address facility siting.  This would include a review of the
locations of each
building and how they could be potentially affected by the ammonia process.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful.
The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-24 00:00:00

Penalty

Initial $7000.00

General-duty citation text

29 CFR 1910.119(e)(3)(vi):  The process hazard analysis did not address
Human Factors:
Throughout the Facility:  The Process Hazard Analysis (PHA) which was
performed in 2009
failed to address human factors analysis.  This would include a review of
the interaction of
the operators/employees with the ammonia system.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful. The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-24 00:00:00

Penalty

Initial $7000.00 · Current $4500.00 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(D):  The employer has failed to develop and
implement an
operating procedure that addresses emergency shutdown which includes the
condition
under
which the shutdown is required, and the assignment of shut down
responsibility.
Throughout the Facility: The employer did not develop an emergency
shutdown procedure
that covers the situations in which an emergency shutdown would be
required nor does it
assign responsibility for initiating a shut down.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful. The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-24 00:00:00

Penalty

Initial $7000.00 · Current $3500.00 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(B):  The employer has failed to develop and
implement an
operating procedure discussing the precautions necessary to prevent
exposure; including
engineering controls, administrative controls, and personal protective
equipment.
Throughout the Facility: The employer did not develop an operating
procedure that that
addresses how the employees will be protected from exposure to anhydrous
ammonia.  The
company has developed basic procedures that discuss the production process
but nothing that
indicates how the employees that work with the chemical are protected or
how they would be
protected in the event of an upset condition i.e. engineering control,
PPE, or some other
method.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful. The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-24 00:00:00

Penalty

Initial $7000.00 · Current $3500.00 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(C):  The employer has failed to develop and
implement an
operating procedure discussing the control measures to be taken if
physical contact or
airborne exposure occurs.
Throughout the Facility: The employer did not develop an operating
procedure that discusses
what actions will be taken in the event of an exposure to anhydrous
ammonia.  The employer
has failed to develop a procedure for response actions for employee
exposure that would
include but is not limited to event escalation, emergency response, or
containment.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful. The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-05-31 00:00:00

Penalty

Initial $7000.00 · Current $4500.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(2):  The employer didn't establish and implement
written procedures to
maintain the on-going integrity of process equipment.
Throughout the Facility:  The employer has not developed any procedures
for ensuring the
mechanical integrity of the system.  This would include a program
outlining preventative
maintenance, component replacement, and/or repair.  One such example would
be a valve
replacement procedure to include a change out schedule for safety relieve
valves.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful. The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-08-31 00:00:00

Penalty

Initial $7000.00 · Current $4500.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(ii):  Inspections and tests of process equipment did
not follow
recognized and generally accepted good engineering practices.
Throughout the Production area, Ammonia transfer components and vessels:
The piping for
the system was not inspected as outlined in any applicable recognized and
generally accepted
good engineering practices.  A portion of the process piping is
underground and can not be
inspected and the exposed piping has only been inspected visually, no
actual thickness testing
has been accomplished.  Two reactor vessels at the facility have been
inspected by plant
personnel; however, those persons do not carry any type of certifications
for this type of
inspection activity.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful.
The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-24 00:00:00

Penalty

Initial $5000.00 · Current $2500.00 Reduced

General-duty citation text

29 CFR 1910.119(k)(2):  Hot work permits utilized by the employer did not
document that
the fire prevention and protection requirements in 29 CFR 1910.252(a) have
been
implemented prior to beginning the hot work operations; the dates(s)
authorized for hot
work; and the identity of the object on which hot work is to be performed.
Throughout the Facility:  The Hot Work Permits being utilized by the
employer did not
document that the fire prevention and protection requirements in 29 CFR
1910.252(a) were
being implemented prior to the beginning of hot work operations nor did it
specify the object
in which the work was to be performed.
Abatement certification is required for this violation. The abatement
certification sheet is
enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-24 00:00:00

Penalty

Initial $7000.00 · Current $3500.00 Reduced

General-duty citation text

29 CFR 1910.119(l)(1):  The employer didn't establish and implement
written procedures to
manage changes to process chemicals, technology, equipment, and
procedures; and changes
to facilities that affect a covered process.
Throughout the Facility:  The employer didn't develop any implement any
written procedures
to ensure that any changes to process equipment included all elements
outlined in the
standard.  This would include the technical basis for the change; the
impact of the change on
safety and health; modifications to the operating procedures; necessary
time period for the
change; and authorization requirements for the proposed change.  The
company implemented
changes to the system in 2010 and did not have a written procedure in
place.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful. The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-24 00:00:00

Penalty

Initial $7000.00 · Current $3500.00 Reduced

General-duty citation text

29 CFR 1910.119(l)(4):  The employer failed maintain or update process
safety
information
after a change was made to the system.
Throughout the Facility:  In June of 2010, the emergency stop system was
replaced with an
air actuated system which was not a replacement in kind.  The employer
failed to update the
process safety information with information regarding the change;
specifically the safety
systems associated with the process.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful. The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-24 00:00:00

Penalty

Initial $7000.00 · Current $3500.00 Reduced

General-duty citation text

29 CFR 1910.119(o)(4):  The employer failed to promptly determine and
document an
appropriate response to each of the findings of the compliance audit, and
document that
deficiencies have been corrected.
Throughout the Facility:  The employer failed to develop a system to track
any identified
deficiencies noted during he Process Safety Management Audit.  There were
six items
identified in the spring 2009 audit and no method to track those open
items until they were
corrected.  The employer has also failed to document that the items have
been corrected.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful. The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-08-31 00:00:00

Penalty

Initial $7000.00 · Current $4500.00 Reduced

General-duty citation text

29 CFR 1910.147(c)(4)(ii):  The energy control procedures did not clearly
and specifically
outline the scope, purpose, authorization, rules, and techniques to be
utilized for the control
of hazardous energy, including, but not limited to the items of this
section:
Throughout the Facility:  Lockout/tagout procedures did not meet the
requirements outlined
above.  The developed procedures are vague in that they do not clearly
specify the
techniques in which lockout operations will be performed and they do not
clearly indicate the
locations where energy may be isolated (switches, valves, breaker numbers,
etc).  Some
equipment examples include but are not limited to the Liqid Plant Norta Rx
and Blender.
Abatement certification and abatement documentation is required for this
violation. The
documentation should include written verification of abatement, applicable
measurements or
monitoring results, and photographs or videos which you believe will be
helpful. The
abatement certification sheet is enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-08-31 00:00:00

Penalty

Initial $5000.00 · Current $3500.00 Reduced

General-duty citation text

29 CFR 1910.147(c)(6)(i):  The employer did not conduct a periodic
inspection of the energy
control procedure at least annually to ensure that the procedure and the
requirement of this
standard were being followed:
Throughout the Facility:  The employer failed to conduct a periodic
inspection of the energy
control procedures as outlined in the standard.
Abatement certification is required for this violation. The abatement
certification sheet is
enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-10 00:00:00

Penalty

Initial $5000.00 · Current $3500.00 Reduced

General-duty citation text

29 CFR 1910.303(g)(2)(i):  Live parts of electric equipment operating at
50 volts  or more
were not guarded against accidental contact by approved cabinets or other
forms of approved
enclosures.
Quonset Hut Storage Area:  There is a live 480 volt electrical line
attached to the east wall
that is not protected from contact by some type of enclosure or by
de-energizing and locking
out the breaker that provides current to the line.
Abatement certification is required for this violation. The abatement
certification sheet is
enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-10 00:00:00

Penalty

Initial $5000.00 · Current $2500.00 Reduced

General-duty citation text

29 CFR 1910.305(b)(2)(i): Pull boxes, junction boxes, and fittings were
not provided with
covers approved for the purpose:
Quonset Hut:  Three electrical boxes located to the east of the main
entrance to the facility
were not provided with a cover to prevent accidental contact with the live
parts within.  The
panels ranged in voltage from 120 to 480.  Covers for two of the panels
were on the floor in
the area and the third has a hinged door that had been left open.
Abatement certification is required for this violation. The abatement
certification sheet is
enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-08-31 00:00:00

Penalty

Initial $6000.00 · Current $3000.00 Reduced

General-duty citation text

29 CFR 1910.305(e)(1): Cabinets, cutout boxes, fittings, boxes, and
panelboard enclosures in
damp or wet locations were not installed to prevent moisture or water from
entering and
accumulating within the enclosures:
North and South Reactor Area:  The electrical enclosures located on the
west wall behind the
reactors are not designed for exposure to water and have become corroded.
Abatement certification is required for this violation. The abatement
certification sheet is
enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-10 00:00:00

Penalty

Initial $3000.00 · Current $1500.00 Reduced

General-duty citation text

29 CFR 1910.305(g)(1)(iv)(A):  Flexible cords and/or cables were used as a
substitute for
the fixed wiring of a structure:
North Reactor Room, East Wall:  An extension cord was plugged into an
outlet used to
power a length of heat tape.  The heat tape is used to prevent a water
line from freezing
when the temperatures drop.
Abatement certification is required for this violation. The abatement
certification sheet is
enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-05-31 00:00:00

Penalty

Initial $5000.00 · Current $2500.00 Reduced

General-duty citation text

29 CFR 1910.1200(h)(3)(iii): Employee training did not include the
measures employees can
take to protect themselves from chemical hazards, including specific
procedures the employer
had implemented to protect employees from exposure to hazardous chemicals:
Throughout the company:  The employer failed to provide training as
prescribed in the
paragraph above in that the employees had not been trained on the hazards
of
the chemicals
that they commonly use including but not limited to Accomplish 3-0-0,
Titan 3-0-0, and
other general lubricants.
Abatement certification is required for this violation. The abatement
certification sheet is
enclosed with the citations.

Issued

2012-01-23 00:00:00

Abate by

2012-02-10 00:00:00

General-duty citation text

29 CFR 1910.178(l)(6):  The employer did not certify that each operator
has been trained
and evaluated as required by this paragraph (l).  The certification shall
include the name of
the operator, the date of the training, the date of the evaluation, and
the identity of the
person(s) performing the training or evaluation.
Throughout the Facility:  The employer failed to ensure that written
certification for each
fork truck operator was written and maintained as outlined in the
standard.
Abatement certification is required for this violation. The abatement
certification sheet is
enclosed with the citations.