OSHA Inspection: WOODWARD IODINE CORPORATION

Issued

Apr 8, 2011

Abate by

May 31, 2011

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.38(c):  The employer did not have procedures that contained
the minimum
elements of an emergency action plan that addressed elements as described
in 29 CFR
1910.38(c)(1) through (5):
The employer does not ensure that the emergency action plan contained
procedures for
reporting a  fire or other emergency; emergency evacuation;  including
type of evacuation
and exit route;  procedures followed by employees who remain to operate
critical plant
operations before they evacuate; accounting for all employees after
evacuation; and
procedures to be followed by employees performing rescue or medical
duties. This exposed
employees to possible fire, burn, and inhalation hazards in the event of
an accident or
explosion.  This violation occurred on or about October 20, 2010 at
Woodward Iodine
Corporation.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of

Issued

Apr 8, 2011

Abate by

May 31, 2011

General-duty citation text

29 CFR 1910.38(f):  Employer did not review the emergency action plan with
each
employee covered by the plan that included the provisions in
1910.38(f)(1)-(3):
The conditions occurred on or about October 20, 2010, and at times prior
thereto, the
employer does not ensure that each employee is informed about the
emergency action plan
and his responsibilities as outlined in the plan. This exposes employees
to possible fire, burn,
inhalation hazards, and death in the event of an accident or explosion.
The
conditions
occurred at the Woodward Iodine Corporation.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including the information required to be reviewed with employees covered
by the emergency
action plan.
A method of abatement is to review the emergency action plan with each
employee covered
by the plan as prescribed in 29 CFR 1910.38(f)(1)-(3).

Issued

Apr 8, 2011

Abate by

May 31, 2011

Issued

Apr 8, 2011

Abate by

May 31, 2011

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.111(b)(3):  Each non-refrigerated container was not marked
with a nameplate
that was permanently attached to the system so as to be readily accessible
and did not contain
markings as prescribed in subdivision (ii) of this paragraph:
The employer does not ensure that the bulk ammonia storage tank V-307 is
permanently
labeled and that the label containes information regarding the contents
(ammonia),

Issued

Apr 8, 2011

Abate by

May 31, 2011

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.111(b)(9):  Each container safety-relief valve used with
systems covered by
paragraphs (c),(f),(g), and (h) of this section was not rated to discharge
in accordance with
the provisions in Table H-36:
The employer does not ensure that the bulk ammonia storage tank V-307 is
equipped with
safety relief valves that discharged at a rate in accordance with the
minimum rate established
in Table H-36. This exposes employees to possible fire, burn, and
inhalation hazards in the
event of an accident.  This violation occurred on or about October 20,
2010 at Woodward
Iodine Corporation.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including the installation of safety relief valve(s) with the required
minimum
discharge rate in
accordance with 29 CFR 1910.111 Table H-36.
A method of abatement is to install safety relief valve(s) that have the
minimum discharge
rate in accordance with 29 CFR 1910.111 Table H-36.

Issued

Apr 8, 2011

Abate by

Apr 27, 2011

General-duty citation text

29 CFR 1910.111(b)(10)(ii):  Stationary storage installations must have at
least two suitable
and approved gas masks in a readily-accessible locations. Full-face masks
with ammonia
cartridges that been approved by NIOSH under 42 CFR part 84 are suitable
for emergency
action involving most anhydrous ammonia leaks, particularly leaks that
occur outdoors. For
respiratory protection in concentrated ammonia atmospheres, a
self-contained breathing
apparatus is required:
The employer does not ensure that the bulk ammonia storage tank V-307 has
at least two
suitable and approved gas masks in readily accessible locations. This
exposes employees to
possible inhalation hazards in the event of an accident.  This violation
occurred on or about
October 20, 2010.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including provide two suitable gas masks in readily-accessible locations.
Full-face masks with
ammonia cartridges that have been approved by NIOSH under 42 CFR part 84
are suitable
for emergency action involving most anhydrous ammonia leaks, particularly
leaks that occur
outdoors. For respiratory protection in concentrated ammonia atmospheres,
a self-contained
breathing apparatus is required.
The method of abatement is to permanently install two full face gas masks
with ammonia
cartridges as prescribed in 29 CFR 1910.111(b)(10)(ii).

Issued

Apr 8, 2011

Abate by

May 31, 2011

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.111(c)(1):  Stationary non-refrigerated ammonia storage
container minimum
design pressure was less than 250 psig:
The employer does not ensure that the bulk ammonia storage tank V-307
maintained a design
pressure of 250 psig. This exposes employees to possible fire, burn, and
inhalation hazards
in the event of an accident.  This violation occurred on or about October
20, 2010.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including evidence to show that the ammonia storage vessel meets the
minimum design
pressure rating of 250 psig.
A method of abatement is to permanently install the newly acquired
non-refrigerated
ammonia storage vessel that meets the minimum design pressure as
prescribed in 29 CFR
1910.111(c)(1).d

Issued

Apr 8, 2011

Abate by

Apr 27, 2011

General-duty citation text

29 CFR 1910.111(f)(9):  At least two chock blocks were not provided and
placed to prevent
rolling of the vehicle whenever it is parked during the loading and
unloading operations:
The employer does not ensure that chock blocks are placed to prevent
rolling of the vehicle
whenever it is parked during loading and unloading operations of anhydrous
ammonia liquid.
This exposed employees to possible fire, burn, and inhalation hazards in
the event of an
accident.  This violation was observed on or about October 28, 2010.
Pursuant to C.F.R. 1903.19, within ten (10) calendar days of the date of
this citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including evidence to show that the at least two chocks are utilized
during loading or
unloading of anhydrous ammonia from a vehicle.
A method of abatement is to use two chock blocks to prevent rolling during
the loading and
unloading of anhydrous ammonia as described in 29 CFR 1910.111(f)(9).

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $2,100 · Current $1,000 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 29 CFR 1910.119:
The employer does not have a written plan of action regarding the
implementation of the
employee participation in regards to such items as process hazards
analysis
(PHA), development
of process safety management (PSM) elements. This exposed employees to
possible fire, burn,
and inhalation hazards in the event of an accident or explosion involving
the release of
anhydrous ammonia, sulfur dioxide, and/or chlorine.  This violation
occurred on or about
October 20, 2010 at Woodward Iodine Corporation.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard,
regarding development of a written plan of action regarding employee
participation.
A method of abatement is to complete the development of a written employee
participation plan
as per 29 CFR 1910.119(c)(1).

Issued

Apr 8, 2011

Abate by

Apr 27, 2011

Penalty

Initial $4,900 · Current $3,000 Reduced

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:
The employer does not have a  completed compilation of written process
safety information
pertaining to safe upper and lower operating limits for the iodine
extraction process such as, but
not limited to SO2 tank, ammonia tank, chlorine tank. This exposes
employees to possible fire,
burn, and inhalation hazards in the event of an accident or explosion.
This violation occurred
on or about October 20, 2010 at Woodward Iodine Corporation plant.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard,
regarding compilation of safe upper and lower operating limits of the
iodine extraction process.
The method of abatement is to complete a compilation of written process
safety information
including but not limited to Safe Upper and Lower Limits and an evaluation
of consequence of
deviations as per 29 CFR 1910.119(d)(2)(i).

Issued

Apr 8, 2011

Abate by

Apr 27, 2011

Penalty

Initial $4,900

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:
The employer does not have a compilation of written process safety
information pertaining to
an evaluation of the consequence of deviation hazards of the iodine
extraction process. This
exposes employees to possible fire, burn, and inhalation hazards in the
event of an accident or
explosion.  This violation occurred on or about October 20, 2010 at
Woodward Iodine facility.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard,
regarding an evaluation of the consequence of deviation from safety upper
and lower operating
limits of the process.
The method of abatement is to complete a compilation of written process
safety
information
including but not limited to an evaluation of consequence of deviations as
per 29 CFR
1910.119(d)(2)(i).E):

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i): Process safety information pertaining to the
equipment in the process
did not include the elements specified in 29 CFR 1910.119(d)(3)(i)(A)
through (H):
The employer does not have complete process safety information pertaining
to the process
equipment including but not limited to materials of construction, piping
and instrument diagrams
(P&ID's), electrical classification, relief system design and design
basis, ventilation system
design and design basis, safety systems (interlocks, detection or
suppression systems), along with
design codes and standards employed. This applied to equipment such as,
but not limited to SO2
tank, chlorine tank, and ammonia tank.This exposed employees to possible
fire, burn, and
inhalation hazards in the event of an accident or explosion.  This
violation was observed on or
about October 20, 2010.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard,
regarding information pertaining to equipment in the process.
A method of abatement is to complete a compilation of information
pertaining to the equipment
in the process including information pertaining to but not limited to
materials of construction,
piping and instrument diagrams (P&ID's), electrical classification, relief
system design and
design basis, ventilation system design and design basis, safety systems
(interlocks, detection or
suppression systems), along with design codes and standards employed.

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $4,900

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 has not documented that the process equipment complies with
recognized and
generally accepted good engineering practices. This exposes employees to
possible fire, burn,
and inhalation hazards in the event of an accident or explosion. For
equipment such as but not
limited toSO2 tank, ammonia tank, chlorine tank. This violation was
observed on or about
October 20, 2010.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard,
regarding equipment complying with RAGAGEP such as, but not limited to,
Chlorine institute,
OSHA 1910.111, for SO2 ASME and API for vessel and piping design and
inspection, ANSI
pumps, NEC for electrical installation and equipment.
A method of abatement is to complete a compilation of information
pertaining to the equipment
in that it complies with recognized and generally accepted good
engineering practices.g

Issued

Apr 8, 2011

Abate by

Apr 27, 2011

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i):  The process hazard analysis did not address the
hazards of the
process:
The employer does not address items in the process hazards analysis such
as
the identification
of previous incidents; engineering and administrative controls
applicability to the hazard;
consequence of failure of engineering and administrative controls;
facility siting; human factors;
and qualitative evaluation of a range of possible safety and health
effects of failure of controls
on employees in the workplace including but not limited to:
1.Evaluate possibility of highly hazardous chemicals accumulating in
sumps, pits or open
ditches that could result in fires, reactions, toxic gas generation etc.
2.Evaluate the possibility that operational controls and interlocks may be
by-passed or over-
ridden.
3.Evaluate the possibility of ingress of flammable/combustible materials
into enclosures
such as control rooms, or analyzer shacks etc, that contain ordinary
electrical equipment.
4.Evaluate the effective control of barriers to protect equipment such as
but not limited to
vessels, tanks, piping, and valve stations containing highly hazardous
chemicals from
vehicular impact.
5.Evaluation of the possibility of inadvertent mixing of highly hazardous
materials.
6.Evaluation of the consequence of power failure.
7.Evaluation of failure of safety devices such as relief devices and the
consequence on
employees in the workplace.
8.Evaluation of expansion pots and/or relief devices where the potential
exists to trap liquid
chlorine.
9.Evaluation of the chlorine system to accumulate nitrogen trichloride in
equipment.
10.Evaluation of unit piping to ensure that it is designed to ensure that
process fluids cannot
backflow into the chlorine system.
11.Evaluation of operators wearing respirator while connecting and
disconnecting chlorine
containers or piping.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding process hazards analysis.
A method of abatement is complete a process hazards analysis that includes
such items as the
identification of previous incidents; engineering and administrative
controls applicability to the
hazard; consequence of failure of engineering and administrative controls;
facility siting; human
factors; and qualitative evaluation of a range of possible safety and
health effects of failure of
controls on employees in the workplace as per 29 CFR 1910.119(e)(3)(i)
through (vii).h

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(5):  The employer did not establish a system to
promptly address the
process hazard analysis team's findings and recommendations:
The employer does not establish a system to promptly address the PHA teams
finding and
recommendations; assure that the recommendations are resolved in a timely
manner and that the
resolution is documented. This exposes employees to possible fire, burn,
and inhalation hazards
in the event of an accident or explosion.  This violation was observed on
or about October 20,
2010. None of the recommendations in the 1999 PHA had been addressed.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding tracking of PHA findings and recommendations.
A method of abatement is to develop a system to address findings and
recommendations; assure
that the recommendations are resolved in a timely manner and that the
resolution is documented;
document what actions are to be taken; complete actions as soon as
possible; develop a written
schedule of when these actions are to be completed; communicate the
actions to operating,
maintenance, and other employees whose work assignments are in the process
and who may be
affected by the recommendations or actions.dations

Issued

Apr 8, 2011

Abate by

Apr 13, 2011

Penalty

Initial $4,900 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(6):  The employer did not ensure after the initial
process hazard analysis
that the process hazard analysis was updated and revalidated at least
every five (5) years by a
team meeting the requirements of 29 CFR 1910.119(e)(4):
The employer does not complete revalidation of the PHA every five (5)
years after completing
the initial process hazards analysis. This exposes employees to possible
fire, burn, and inhalation
hazards in the event of an accident or explosion.  This violation occurred
on or about October
20, 2010.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding revalidation of the initial PHA.
A method of abatement is to complete revalidation of the initial process
hazards analysis (PHA).is

Issued

Apr 8, 2011

Abate by

May 1, 2012

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1):  The employer did not develop and implement written
operating
procedures that provided clear instructions for safety conducting
activities in each covered
process consistentwith the process safety information and which addressed
the elements listed
in 29 CFR 1910.119(f)(1)(i)(A) through (f)(1)(i)(G):
The employer has not developed and implemented written operating
procedures that provided
clear instructions for safely conducting activities in the various
operating phases such as but not
limited to Temporary Operations, Emergency Shutdown, Normal Shutdown, or
Start-up
following a turnaround, and or after an Emergency Shutdown.  This
violation occurred on or
about October 20, 2010.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding operating procedures including steps for each operating phase.
A method of abatement is to complete development and implementation of
operating procedures
that provide clear instructions for safely conducting activities involved
in each phase of the
process such as but not limited to Temporary Operations, Emergency
Shutdown including
conditions where emergency shutdown is required, Normal Shutdown, or
Start-up following a
turnaround, and or after an Emergency Shutdown as per 29 CFR
1910.119(f)(1)(i)(A) through
(G).ugh

Issued

Apr 8, 2011

Abate by

May 1, 2012

General-duty citation text

29 CFR 1910.119(f)(1)(ii):  The employer's written operating procedures
did not address the
requirements for the operating limits listed in 29 CFR
191.119(f)(1)(ii)(A) and (B):
The employer has not developed and implemented written operating
procedures that provide
clear instructions for safe operating limits including consequence of
deviation and steps required
to correct or avoid deviations.  This violation was observed on or about
October 20, 2010.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding operating limits.
A method of abatement is to complete development and implementation of
operating
procedures
that provide clear operating limits, consequences of deviation from those
limits and instructions
and steps required to avoid or correct the deviation as per 29 CFR
1910.119(f)(1)(ii)(A) through
(B).ugh

Issued

Apr 8, 2011

Abate by

May 1, 2012

General-duty citation text

29 CFR 1910.119(f)(1)(iv):  The employer's written operating procedures
did not address
requirements for the safety systems and their functions:
The employer has not developed and implemented written operating
procedures that addressed
Safety Systems and their functions.  This violation occurred on or about
October 20, 2010.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding operating procedures Safety Systems and their functions.
A method of abatement is to complete development and implementation of
operating procedures
that document all safety systems and their functions as per 29 CFR
1910.119(f)(1)(iv).

Issued

Apr 8, 2011

Abate by

May 1, 2012

Penalty

Initial $2,100 · Current $3,000

General-duty citation text

29 CFR 1910.119(g)(1)(ii):  In lieu of initial training for those
employees already involved in
operating a process on May 26, 1992, the employer did not certify in
writing that the employee
had the required knowledge, skills, and ability to safety carry out the
duties and responsibilities
as specified in the operating procedures:
The employer does not train employees involved in operating a process in
an overview of the
process and operating procedures and provide refresher training at least
every three years. The
employer does not ascertain that each employee received and understood the
training required
nor that the training that was received was recorded with the identity of
the employee, date of
training, and the means to verify that the employee understood the
training received. This
violation occurred on or about October 20, 2010.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the
standard
regarding training of employees involved in operating a process.
The method of abatement is to complete training of all employees involved
in operations in an
overview of the process and operating procedures and provide refresher
training at least every
three years; ascertain that each employee received and understood the
training required and that
the training that was received was recorded with identity of the employee,
date of training, and
the means to verify that the employee understood the training received as
per 29 CFR
1910.119(g)(1) through (g)(3).

Issued

Apr 8, 2011

Abate by

May 1, 2012

Penalty

Initial $2,100 · Current $3,000

General-duty citation text

29 CFR 1910.119(h)(2)(i):  The employer, when selecting a contractor, did
not obtain and
evaluate information regarding the contract employer's safety performance
and programs:
The employer does not evaluate information regarding contractors'(Pasadena
Tank Corporation)
safety performance and programs prior to the contractor performing work
within the covered
process. This violation occurred on or about October 20, 2010.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding contractor safety performance.
A method of abatement is to evaluate safety information and programs of
all contractor
performing working within covered process as per 29 CFR 1910.119(h)(2)
through (vi).gh

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $2,100 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(h)(2)(ii):  The employer did not inform contract employers
of the known
potential fire, explosion, or toxic release hazards related to the
contractor's work and the
process:
The conditions occurred on or about October 22, 2010. The employer does
not fully inform
contract employers exposed to chemicals including but not limited to
methanol, diesel, gasoline,
ammonia, sulfur dioxide, hydrogen sulfide , and chlorine gas hazards at
the workplace in
relation to their work process at the Woodward Iodine Corporation.
Pasadena
Tank Corporation
employees started work on installation of an IRW tank on October 18, 2011.
On October 22,
2011 they stated to OSHA that they did not know what were the hazards on
site. Training
information provided to OSHA days later was dated October 25, 2011.
Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of
this citation, the
employer must submit documentation describing the steps it is taking to
ensure that contract
employers are notified of hazards at the work place in relation to their
work in a covered
process.
The method of abatement is to inform contractors prior to working on or
near a covered process
about the hazards related to their work as required by the information
described in 29 CFR
1910.119(h)(2)(ii).

Issued

Apr 8, 2011

Abate by

Apr 27, 2011

Penalty

Initial $2,100 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(h)(2)(vi):  The employer did not maintain a contract
employee injury and
illness log related to contractor's work in process areas:
The condition was observed on or about October 20, 2010. The employer does
not maintain a
contract employee injury and illness log related to the contractor's work
in the process areas at
the Woodward Iodine Corporation, for Pasadena Tank Corporation employees
installing an IRW
tank.
Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of
this citation, the
employer must submit documentation describing the steps it is taking to
ensure that the written
process safety information is completed.
The method of abatement is to maintain a contract employee injury and
illness log related to the
contractor's work in process areas as required by the information
described in 29 CFR
1910.119(h)(2)(vi).

Issued

Apr 8, 2011

Abate by

May 1, 2012

Penalty

Initial $4,900 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(1)(i)(A):  The employer did not have startup
operating procedures.
The employer does not startup operating procedures for new and or modified
facilities
such as
but not limited to the replacement of the chlorine cylinders with a bulk
liquid chlorine tank;
addition of a second chlorine evaporator; removal of the ammonia vapor
compressor;
modification and rerating of the ammonia storage tank, and removal of the
sulfur dioxide vapor
compressor. This violation occurred on or about October 20, 2010 at
Woodward Iodine
Corporation.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding pre-startup safety reviews.
A method of abatement is to develop and implement startup operating
procedures per 29 CFR
1910.119(f)(1)(i)(A).A):

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $4,900 · Current $4,900

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:
The employer does not develop and implement written procedures to maintain
the ongoing
integrity of process equipment such as but not limited to the Anhydrous
Ammonia, Liquid
Chlorine, and Sulfur Dioxide storage tanks and their associated piping,
and process equipment.
This violation occurred on or about October 20, 2010 at Woodward Iodine
Corporation.
Management stated to OSHA that they did not have written mechanical
integrity programs.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding written procedures to maintain mechanical integrity of process
equipment.
The method of abatement is to develop a program with written procedures to
maintain process
equipment such as but not limited to the Anhydrous Ammonia, Liquid
Chlorine, and Sulfur
Dioxide storage tanks, their associated piping, and process equipment as
per
29 CFR
1910.119(j)(2).

Issued

Apr 8, 2011

Abate by

May 1, 2012

Penalty

Initial $4,900

General-duty citation text

29 CFR 1910.119(j)(3):  The employer did not train each employee involve
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
asssure that the employee
can perform the job tasks in a safe manner:
The employer does not train each employee involved in maintaining the
ongoing integrity of
process equipment and in the procedures applicable to the employee's tasks
to assure that the
employee can perform the job tasks in a safe manner. This violation
occurred on or about
October 20, 2010 at Woodward Iodine Corporation.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard training
of employees involved in maintaining the ongoing integrity of process
equipment and in the
procedures applicable to the employee's tasks to assure that the employee
can perform the job
tasks in a safe manner.
The method of abatement is to develop and train each employee involved in
maintaining the
ongoing integrity of process equipment and in the procedures applicable to
the employee's tasks
to assure that the employee can perform the job tasks in a safe manner as
per 29 CFR
1910.119(j)(3).

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $4,900

General-duty citation text

29 CFR 1910.119(j)(4)(i):  Inspections and tests were not performed on
process equipment to
maintain its mechanical integrity:
The employer does not develop and implement inspection and testing to
maintain the ongoing
integrity of process equipment such as but not limited to the Anhydrous
Ammonia, Liquid
Chlorine, and Sulfur Dioxide storage tanks and their associated piping,
and process equipment.
This violation occurred on or about October 20, 2010.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of
this citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding mechanical integrity testing and inspection.
The method of abatement is to develop a program to perform mechanical
integrity inspections
and testing of process equipment as per 29 CFR 1910.119(j)(4)(i) through
(iv).gh

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $3,500

General-duty citation text

29 CFR 1910.119(j)(6)(iii):  The employer did not assure that maintenance
materials, spare parts
and equipment were suitable for the process application for which they
were used:
The conditions were observed on or about October 20, 2010. The employer
does not ensure that
new equipment installed was suitable for the process application.  The
conditions were observed,
as noted in (a) through (c) below, at the Woodward Iodine Corporation:
a)In replacing the flame arrestor the employer uses a tank plate/label in
order to
purchase the new flame arrestor.  The employer substituted the material of
construction for the tank from carbon steel to stainless steel and did not
ensure
that the material was compatible with the process.
b)Potable water tank T-303 was replaced and original specifications were
not used.
c)The sulfuric acid tank V-302 was replaced without meeting original
specifications.
Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of
this citation, the
employer must submit documentation describing the steps it is taking to
ensure that the written
mechanical integrity information is completed.
The method of abatement is to use equipment suitable for the process for
which they will be
used as described in 29 CFR 1910.119(j)(6)(iii).

Issued

Apr 8, 2011

Abate by

Apr 27, 2011

Penalty

Initial $4,900 · Current $3,000 Reduced

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 conditions were observed on or about October 20, 2010. The employer
does not issue a hot
work permit for IRW tank being constructed near a covered process.
Pasadena Tank Corporation
was erecting the tank south of the 72,000 pounds anhydrous ammonia tank
and 78,000 pounds
sulfur dioxide tank at the Woodward Iodine Corporation.
Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of
this citation, the
employer must submit documentation describing the steps it is taking to
ensure that the written
hot work permit information is completed.
The method of abatement is to ensure that hot work permits are issued in
accordance with the
required information as described in 29 CFR 1910.119(k)(1).

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $4,900 · Current $3,000 Reduced

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:
The employer does 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. This violation occurred on or about October 20, 2010.
Instances:
1. Changing from 1000 lbs chlorine container to a bulk storage tank.
2. Compressor for ammonia system removed from plant.
3. The sulfur dioxide system does not have a vapor compressor installed,
but the SOP unloading
instructions are in place as if the compressor is still installed.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding management of change.
The method of abatement is to establish and implement a written process
and procedure to
manage changes to process chemicals, technology, equipment, and
procedures; and changes to
facilities that effect a covered process as per 29 CFR 1910.119(l)(1)
through (5).ugh

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(m)(1):  The employer did not investigate each incident
which resulted in, or
could reasonably have resulted in, a catastrophic release of a highly
hazardous chemical in the
workplace:
The conditions were observed on or about October 20, 2010. The employer
does not comply
with the provisions of this section and did not initiate an incident
investigation of each incident
which resulted in or could reasonably have resulted in a catastrophic
event of highly hazardous
chemical in the work place; within 48 hours of the incident; there is no
incident investigation
team established; there were no reports prepared that included: date,
time, description,
contributing factors, and recommendations; there was no system in place to
address and resolve
findings; reports were not reviewed with affected personnel; and reports
were not retained for
5 years.
On April 6, 2009, there was an over-pressurization of the 72, 000 pound
anhydrous ammonia
tank. The contract worker was unloading ammonia when the truck driver over
pressured the tank
pop
off valve. On December 22, 2009 there was a repair of an SO2 leak on the
second floor of the
200 area and on March 30, 2010 a chlorine leak was repaired in the 700
area. None of the
information received contained the required elements specified in 29 CFR
1910.119(m)(1)(7).
Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of
this citation, the
employer must submit documentation describing the steps it is taking to
ensure that the incident
investigations are completed on each incident which resulted in or could
reasonably have resulted
in a catastrophic event of highly hazardous chemical in the covered
process.
The method of abatement is to ensure that incident investigations be
investigated and documented
in accordance with the required information as described in 29 CFR
1910.119(m)(1)-(7).

Issued

Apr 8, 2011

Abate by

Apr 27, 2011

Penalty

Initial $2,100 · Current $1,000 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 29 CFR 1910.119 at least every three years to verify
that the procedures and
practices developed under this standard were adequate and are being
followed:
The conditions occurred on or about October 20, 2010. The employer does
not comply with the
provisions of this section and does not certify that they have 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 an are being followed.  These
conditions were
observed at the Woodward Iodine Corporation.
Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of
this citation, the
employer must submit documentation describing the steps it is taking to
ensure
that the written
process safety information is completed.
The method of abatement is to ensure that they have 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 in accordance with
the required
information as described in 29 CFR 1910.119(o)(1).

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(o)(4):  The employer did not determine and document an
appropriate response
to each of the findings of the compliance audit required by 29 CFR
1910.119(o)(1), and
document that the deficiencies had been corrected:
The conditions were observed on or about October 20, 2010. The employer
does not comply
with the provisions of this section and does not promptly determine and
document an appropriate
response to each of the findings of the compliance audit, and does not
document that the
deficiencies had been corrected.  This exposes employees to possible fire,
burn, inhalation
hazards, and death in the event of an accident or explosion.  The
conditions were observed at
the Woodward Iodine Corporation. There is no documentation to show that
the 1999 PHA
recommendations had been completed or are being addessed; the deficiencies
still exist.
Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of
this citation, the
employer must submit documentation describing the steps it is taking to
ensure that the written
process safety information is completed.
The method of abatement is to promptly determine and document an
appropriate response to
each of the findings of the compliance audit, and document that the
deficiencies have been
corrected in accordance with the required information as described in 29
CFR 1910.119(o)(4).

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $3,500 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.120(q)(6)(iii)(A):   Employees who participated or were
expected to participate,
as hazardous material technicians had not received at least 24 hours of
training equal to the first
responder operations level and/or had not been certified as having such
training

Issued

Apr 8, 2011

Abate by

May 1, 2012

Penalty

Initial $3,500 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.132(d)(2):  The employer did not verify, through a written
certification,
that the
required workplace hazard assessment had been performed:
The conditions were observed on or about October 20, 2010. The employer
does not assess the
work place to determine if hazards are present for employees exposed to
chemicals including but
not limited to 93% sulfuric acid, anhydrous ammonia, sulfur dioxide,
hydrogen sulfide , and
liquid chlorine at the Woodward Iodine Corporation.
Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of
this citation, the
employer must submit documentation describing the steps it is taking to
ensure that the a hazard
assessment and equipment selection is performed.
A method of abatement is to assess the workplace to determine if hazards
are present which
nessesitate the use of personal protective equipment.

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.134(c)(1):  In the workplace where respirators were required
by the employer to
be worn, the employer did not establish and implement a written
respiratory program which met
the requirements of (c)(1)(i) to (ix) of this section and specific to the
workplace where the
respiratory protection was required and in use:
The condition was observed on or about October 19, 2010. The employer does
not have a
written respirator program with procedures, guidelines and training
specific to Woodward Iodine
Corporation hazards.  Employees have potential exposures to chemicals
including but not limited
to 93% sulfuric acid, ammonia, sulfur dioxide, hydrogen sulfide, and
chlorine gas.
1. The only respirators observed had organic vapor cartridges which do not
protect against any
of the substances mentioned above.
2. Several employees had been wearing respirators without annual
fit-testing.
3. Employees had been wearing respirators without a medical clearance.
Pursuant to 29 CFR 1903.19, within ten (10) calendar days of the date of
this
citation, the
employer must submit documentation describing the steps it is taking to
ensure that the written
respiratory protection program is completed.
The method of abatement is to prepare and implement a written respiratory
protection program,
specific to the workplace, that complies with 29 CFR 1910.134(c)(1)(i) to
(ix).

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.147(c)(2)(ii): Where an energy isolating device was capable of
being locked out,
the employer's energy control program under 29 CFR 1910.147 (c)(1) did not
utilize a lockout
program or a tagout program as set forth in paragraph (c)(3):
The employer did not demonstrate that a level of safety is achieved in the
tagout program which
is equivalent to the level of safety obtained by use a lockout program
while replacing a leaking
valve on the line from the cyclone and crystallizers. This violation was
observed on or about
October 28, 2010 at Woodward Iodine Corporation.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of
this citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding tagout systems and providing a level of safety equivalent to
that of a lockout program.
A method of abatement is to provide additional safety measures in the
tagout program such as
the removal of an isolation circuit/pipe segment, blocking of a
controlling switch, opening and
extra disconnecting device, double block and bleeds, blinding, or removal
of valve handles as
per 29 CFR 1910.147(ii).

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

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 items (a) through (d) of
this section:
The employer does not provide energy control procedures that would clearly
and specifically
outline the scope, purpose, authorization, rules, and techniques to be
utilized for the control of

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

General-duty citation text

29 CFR 1910.147(c)(5)(ii) (C)(2): Tagout device attachment means were not
of a non reusable
type, attachable by hand, self-locking, and non releasable with a minimum
unlocking strength
of no less than 50 pounds (that is, having the general design and basic
characteristic of being
at least equivalent to a one-piece, all-environment-tolerant nylon cable
tie):
The employer does not provide tagout devices that were substantial enough
to prevent
inadvertent or accidental removal when it used string to attach the tag to
the device while
replacing a leaking valve on the line from the cyclone and crystallizers.
This violation was
observed on or about October 28, 2010.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding means of attachment of tagout devices.
A method of abatement is to provide and utilize a means of attaching
tagout devices that are
substantial and have a minimum unlocking strength of 50 lbs and have a
general design and
characteristics of being at least equivalent to a one-piece, all
environment tolerant nylon cable
tie section as per 29 CFR 1910.147(c)(5)(ii)(C)(2).

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $4,900 · Current $3,000 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:
The employer does not conduct a periodic inspection of the energy control
procedure at least
annually to ensure that the procedure and the requirements of the standard
were being followed.
This violation occurred on October 20, 2010 and at times prior thereto.
Pursuant to  29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding at least annual periodic inspections of energy control
procedures.
A method of abatement is to perform periodic inspections at least annually
of the energy control
procedures and certify that the period inspection were preformed as per 29
CFR
1910.147(c)(6)(i)A through (D) and 29 CFR 1910.147(c)(6)(ii).

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

General-duty citation text

29 CFR 1910.147(c)(7)(i): The employer did not provide training to ensure:
1) that the purpose
and function of the energy control program was  understood by the
employees and 2) that the
knowledge and skills required for the safe application, usage and removal
of the energy controls
was  acquired by the employees:
The employer does not provide adequate training to ensure that the purpose
and function of the
energy control program are understood by all employees and that the
knowledge and skills
required for safe application, usage, and removal of the energy control
are acquired by the
employees. In addition, the employer does not certify that such training
had been accomplished.
This violation occurred on or about October 20, 2010 at Woodward Iodine
Corporation.
Employees are not familiar with Lockout/Tagout procedures.Each employee
does LOTO in a
different way.
Pursuant to C.F.R. 1903.19, within ten (10) calendar days of the date of
this
citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding training on energy control procedures and programs.
A method of abatement is to develop and provide training to ensure that
the purpose and function
of the energy control program are understood by all employees and that the
knowledge and skills
required for safe application, usage, and removal of the energy control
are acquired by the
employees and to certify that the training had been accomplished as per 29
CFR
1910.147(c)(7)(i)(A) through (C), 29 CFR 1910.147(c)(7)(ii)(A) through
(F), and 29 CFR
1910.147(c)(7)(iv).A)

Issued

Apr 8, 2011

Abate by

Nov 1, 2011

Penalty

Initial $4,900

General-duty citation text

29 CFR 1910.147(d): The established procedure for the application of
energy control (the
energy control procedure) was not done in sequence and it did not contain
the elements as
required by 29 CFR 1910.147(D)(1) through (d)(6):
The employer does not establish a procedure for the application of energy
control (the lockout
or tagout procedures) taht cover application of control such as
preparation for shutdown;
machine and equipment shutdown; machine equipment isolation; lockout or
tagout device
application; release of stored energy; and verification of isolation. This
violation was observed
on or about October 20, 2010 while replacing a leaking valve on the line
from the cyclone to
the crystallizer. Section (c)(4)(i) of LOTO not being followed during a
valve change. Section
There was a procedure for the sweetner tower but  it lacked the sequence
of LOTO as defined
in the standard.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard
regarding at least annual periodic inspections of energy control
procedures.
A method of abatement is to develop and implement procedures for the
application of energy

Issued

Apr 8, 2011

Abate by

Apr 27, 2011

Penalty

Initial $3,500 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.169(a)(2):  A new receiver installed after the effective date
of these regulations
was not constructed in accordance with the 1968 Edition of the ASME Boiler
and Pressure
vessel code Section VIII.
The employer has not ensured that the compressed air receiver vessel was
constructed in
accordance with the 1968 A.S.M.E. Boiler and Pressure Vessel Code Section
VIII. This
exposes employees to possible fatal injury as a result of catastrophic
failure of the high
pressure vessel. There was not a U1; vessel did not have a name plate
either ASME or API,
the employer could not find any information on the tank. Management said
it was not a
coded vessel. This violation occurred on or about October 20, 2010.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard,
including the information required to be contained on the permanently
installed nameplate.
The method of abatement is to install a compressed air receiver that meets
the 1968
A.S.M.E. Boiler and Pressure Vessel Code Section VIII as prescribed in 29
CFR
1910.169(a)(2).

Issued

Apr 8, 2011

Abate by

May 1, 2012

Penalty

Initial $4,900 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.305(a)(2)(i):  Temporary electrical power and lighting
installations rated 600
volts, nominal, or less were used for purposes other than those permitted
in subparagraphs (a),
(b) and (c) of this paragraph:
The employer does not ensure temporary electrical power and lighting
installations rated 600
volts, nominal, or less are used for purposes other than those permitted.
Floor
fans were being
powered with extension cords in the utilities building and the extension
cord was being run
through their fuel storage tank/vessel and had been for a while.  They
were also used for heat
tracing throughout the plant  specifically near the sulfur dioxide tank.
This exposes employees
to electrical burns and electrocution death.  This violation was observed
on or about  October
20, 2010.
Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the date
of this citation, the
employer must submit documentation showing that it is in compliance with
the standard,
regarding temporary electrical power installations.
The method of abatement is to replace temporary wiring used for power to
equipment and other
devices are replaced with permanent wiring as prescribed in 29 CFR
1910.305.d

Issued

Apr 8, 2011

Abate by

May 1, 2012

General-duty citation text

29 CFR 1910.305(b)(1):  Conductors entering boxes, cabinets, or fittings
were not protected
from abrasions:

Issued

Apr 8, 2011

Abate by

May 1, 2012

General-duty citation text

29 CFR 1910.305(b)(2):  Pull boxes, junction boxes, and fittings were not
provided with covers
approved for the purpose: