OSHA Inspection: DAC AEROSOL & LIQUID FILL

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

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 29 CFR 1910.119:
The employer did not develop a written plan of action regarding the
implementation of
employee participation.
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 citation(s).

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

General-duty citation text

29 CFR 1910.119(d)(2)(i)(D):  Process safety information pertaining to the
technology of the
process did not include the safe upper and lower limits for such items as
temperatures,
pressures, flows or compositions:
Safe upper and lower limits for temperature, pressure of propellant stored
in tanks was
not established. Documents were not available for temperature and pressure
variations
of the tank contents.
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 citation(s).n

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

General-duty citation text

29 CFR 1910.119(d)(2)(i)(E):  Process safety information pertaining to the
technology of the
process did not include an evaluation of the consequence of deviations,
including those affecting
the safety and health of employees:
Aerosol can leak testing water bath with defective thermostat that was
likely to cause
temperature and pressure extremities on the cans was not evaluated.
Several incidents of
the aerosol can exploding causing near misses, and serious injuries to
employees were
reported and noted. No evaluation of the condition and measure to abate
the
condition
was taken.
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 citation(s).

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

General-duty citation text

29 CFR 1910.119(d)(3)(i)(A):  Process safety information pertaining to the
equipment in the
process did not include the materials of construction:
Materials of construction for the pipes, control valves, gas house
equipment, such as
crimpers, gas chargers, electrical and,test bath water tank thermostat,
heating elements
were not made available.
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 citation(s).

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

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 the piping and instrument diagrams (P&ID'S):
The documents provided during the inspection did not include instrument
diagrams(P&ID'S).
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 citation(s).

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D):  Process safety information pertaining to the
equipment in the
process did not include the relief system design and design basis:
The design and design basis for the pressure relief system on 6565 gallon
storage tank
was not documented.
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 citation(s).n

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

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:
The employer did not document the following RAGAGEP were followed:
a. Where flammable chemicals such as acetone, ethyl ether, toluene and
isopropyl
alcohol were used as base product, mechanical exhaust ventilation was not
installed at
the filling station.(NFPA 30B 4.4.3, 2007 Edition)
b. The aerosol container test bath was not enclosed and equipped with
exhaust
ventilation.(NFPA 30B 5.4.4, 2007 Edition)
c. Where chemicals were likely to spill on the floor of the base chemical
filling line,
drainage systems were not provided to direct the leaks in to a safe
location (NFPA 30B
5.10.1, 2007 Edition).
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 citation(s).

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

General-duty citation text

29 CFR 1910.119(e)(1): The employer did not perform an initial process
hazard analysis (hazard
evaluation) on processes covered by 29 CFR 1910.119:
Where the employer utilized mixture of Liquid Petroleum Gas(LPG), such as
propane,
isobutane and n-butane, which are classified Class A flammable liquid, the
employer did
not perform an initial process hazard analysis as required by Process
Safety
Management(PSM).
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 citation(s).

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

General-duty citation text

29 CFR 1910.119(f)(1)(i)(B): Operating procedures for normal operations
was not developed and
implemented.
Written operating procedures were not developed and implemented for daily
operations
at the storage tank, of the gas house equipments, base chemical filling,
test bath tank,
aerosol can capping, packing, storing and shipping operations.
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 citation(s).n

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

General-duty citation text

29 CFR 1910.119(g)(1)(i):  The employer did not initially train each
employee, presently
involved in operating process, in a overview of the process and in the
operating procedures as
specified in 29 CFR 1910.119(f).
Initial training was not provided to any one of the employees who were
involved in the
aerosol filling operation.
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 citation(s).

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

General-duty citation text

29 CFR 1910.119(h)(2)(iii):  The employer did not explain to contract
employers the applicable
provisions of the emergency action plan required by 29 CFR 1910.119(n):
On or about 06/16/2010, the employer did not inform the electric contract
employer
(CEC, Inc.) of the provisions of the emergency action plan when discussing
about a
repair to be done on a propane motor starter.
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 citation(s).

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

General-duty citation text

29 CFR 1910.119(i)(2)(i): The pre-startup safety review did not confirm
that prior to the
introduction of highly hazardous chemicals to the process, that
construction and equipment were
in accordance with design specifications:
a.The pre-startup safety review did not identify the lack of exhaust
ventilation
at the
base chemical filling.
b. The pre-startup safety review did not identify the lack of exhaust
ventilation at the
hot water bath tank.
c.The Pre-startup safety review did not identify that drainage system was
not
installed in the floor where flammable chemicals were likely to spill.
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 citation(s).n

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

General-duty citation text

29 CFR 1910.119(j)(2):  The employer did not establish and implement
written procedures to
maintain the on-going mechanical integrity of process equipment:
A written mechanical integrity program was not developed and implemented
for
the
aerosol can filling line prior to the beginning of the operation.
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 citation(s).n

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

General-duty citation text

29 CFR 1910.119(j)(3):  The employer did not train each employee involved
in maintaining the
on-going mechanical integrity of process equipment in an overview of that
process and its
hazards and in the procedures applicable to the employee's job tasks to
assure that the employee
can perform the job tasks in a safe manner:
The mechanic who was assigned to work on the covered process equipment
such as the
base chemical filling line, the hot water tank system and or miner
operations in the gas
house was not given training on the safe operation 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 citation(s).

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

General-duty citation text

29 CFR 1910.119(k)(1):  The employer did not issue a hot work permit for
work operations
conducted on or near a covered process:
The Mechanic was permitted to weld on the canner line without work permit.
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 citation(s).n

Issued

Nov 9, 2010

Abate by

Dec 3, 2010

Penalty

Initial $2,000 · Current $2,000

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:
Management Of Change(MOC) was not developed and implemented for the
following
equipment:
a. In the spring of 2010, alteration of the electrical system of the
heating elements from
2 phase, 480 volts to a three phase, 380 volts.
b. On or 08/18/2010, a meat temperature tester(thermometer) to replace a
damage
thermostat in the hot water test tank.
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 citation(s).