OSHA Inspection: ORICA

Issued

2011-09-07 00:00:00

Abate by

2011-09-12 00:00:00

Penalty

Initial $5000.00 · Current $3750.00 Reduced

General-duty citation text

29 CFR 1910.23(a)(2):  Ladderway floor opening(s) or platform(s) were not
provided with
swinging gates or were not so offset that a person could not walk directly
into the opening:
Employee(s) climbing a fixed ladder to gain access to an upper level
platform in the mix room
at the Detagel building were exposed to a fall hazard of approximately 84
inches due to no swing
gate being provided.
29 CFR 1903.19(c)(2) abatement of the above violation was verified at the
time of
inspection.  No certification is required.tion

Issued

2011-09-07 00:00:00

Abate by

2012-03-05 00:00:00

Penalty

Initial $4000.00 · Current $3000.00 Reduced

General-duty citation text

29 CFR 1910.119(c)(2):   The employer did not consult with employees and
their representative
on the development of elements of process safety management:
At the establishment employee(s) had not been consulted on the conduct and
development of the
following elements of the process safety management program:
(a)process safety information
(b)process hazard analysis
(c)process safety management training
(d)contractors
(e)mechanical integrity
(f)hot work permits
(g)management of change
(h)incident investigations
(i)emergency planning and response
(j)compliance audits
(k)trade secrets
Employee(s) were exposed to workplace hazards such as, but not limited to
the detonation of
explosive materials which have historically resulted in death and injury
to
persons in and near
the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

2011-09-07 00:00:00

Abate by

2012-09-07 00:00:00

Penalty

Initial $4000.00 · Current $3000.00 Reduced

General-duty citation text

29 CFR 1910.119(d):   The employer did not develop a written compilation
of process safety
information on hazardous chemicals in the process, the technology of the
process, and the
equipment in the process before conducting the process hazard analysis:
Employee(s) working in the Detagel building did not have access to the
process safety
information for the following equipment:
(a)no written process safety information for the LaMot rupture disc that
is attached to pump
(P307).
(b)no written process safety information for the 2 inch stainless steel
piping in the Detagel
production packaging room.
(c)no written process safety information for the flexible piping being
used between the
aluminum feeder valve (V319) and the ribbon mixer (RM301); and on the
south KP
machine below the walk platform.
(d)incomplete process safety information for the ribbon mixer (RM301), the
process
equipment data sheet for the ribbon mixer (RM301) was missing the
electrical
classifications, flow/head curve, high/low limits (capacity, throughput
rate, speed,
pressure, temperature), design codes, driver/sealing arrangement, and etc.
(e)incomplete process safety information for pump (P307), the employer did
not provide the
safe upper and lower operating pressures for product pump (P307).
Employee(s) were exposed to workplace hazards such as, but not limited to
the detonation of
explosive materials which have historically resulted in death and injury
to persons in and near
the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

2011-09-07 00:00:00

Abate by

2012-09-07 00:00:00

Penalty

Initial $5000.00 · Current $3750.00 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 the piping and instrument diagrams (P&ID'S):
At the Detagel building, the employer had not verified that the P&ID's
were up to date and
accurate for use by Orica employee(s) and contractors for line breaks,
equipment / piping
replace or repairs, and etc.  Piping circuits were evaluated and the
following was noted:
(a) Two gate valves located at the bottom of the Ammonium Nitrate tank
(TA301) were not
labeled on the P&ID, drawing number DG-1001.
(b) The capped line branching from PL309-2 that was entering the Sump
Water Recycle tank
was observed during the walk around, but not drawn on the P&ID number
DG-1001.
(c) A valve (V327) noted on the P&ID number DG-1001 under the Product
Recycle Tank
(TA302) observed during the walk around.
(d) A flange under the Product Recycle Tank (V327) was observed during the
walk around,
but was not drawn on the P&ID number DG-1001.
(e) A plastic union was observed after pump (P305) under the Product
Recycle Tank (V327),
but was not drawn on the P&ID number DG-1001.
(f) A plastic union was observed after the 2" wire strainer on pipe line
(PL305-2) for the
Product Recycle Tank (V327), but was not drawn on the P&ID number DG-1001.
(g) A flange was observed after gate valve (V335) and before gate valve
(VV382) on pipe
line (PL305-2) for the Product Recycle Tank (V327), but was not drawn on
the P&ID
number DG-1001.
(h)A flange was observed on pipe line (PL310-2) after gate valve (V310)
and
before the 2"
stainless steel flexible piping, but was not drawn on the P&ID number
DG-1001.
(i)A flange was observed on pipe line (PL310-2) after the 2" stainless
steel flexible pipe,
but was not drawn on the P&ID number DG-1001.
(j)A flange was observed on the pipe line for the hand fed Guar, but was
not drawn on the
P&ID number DG-1001.
(k)A flange was observed on the pipe line for the hand fed Cross Linker,
but was not drawn
on the P&ID number DG-1001.
(l) Piping from the aluminum feeder gate valve (V319) was observed during
the walk around
as a flexible piping, but drawn on the P&ID as rigid piping connecting to
a stainless steel
pipe that entered the ribbon mixer (RM301).
(m) A flange was observed at the bottom of process tank (T305), but was
not drawn on the
P&ID number DG-1002.
(n)A flange was observed on pipe line (PL315-2) after gate valve (V336),
but was not
drawn on the P&ID number DG-1002.
(o)A plastic union was observed on pipe line (PL315-2) after gate valve
(V336), but was
not drawn on the P&ID number DG-1002.
(p)A flange was observed below the flexible piping of process tank (T306)
that attached
pump (P307), but was not drawn on the P&ID number DG-1002.
(q)The pipe line exiting process tank T306 to the FiliPac PLC was not
labeled on P&ID
number DG-1002.
(r)A flange was observed on the piping exiting pump (V393), but was not
drawn on the
P&ID number DG-1002.
(s)A flange was observed after the rupture disk (RD301) and before the
pipe
reducer (4x2),
but was not drawn on the P&ID number DG-1002.
(t)A flange was observed on the pipeline exiting process tank T306 after a
3-way valve
(V393) and flexible pipe, but was not drawn on the P&ID number DG-1002.
(u)A second flange was observed on the pipeline exiting process tank T306
after a 3-way
valve (V393) and flexible pipe, but was not drawn on the P&ID number
DG-1002.
(v)A pipe coupler was observed after the second flange on the pipeline
exiting process tank
after a 3-way valve (V393) and flexible pipe, but was not drawn on the
P&ID number
DG-1002.
(w)A pressure regulator for an air valve (V355) was observed during the
walk around, but
was drawn on the P&ID number DG-1002.
(x)A flange was observed before air valve (V355) during the walk around,
but
was not
drawn on the P&ID number DG-1002.
(y)A flange was observed after air valve (V355) during the walk around,
but was not drawn
on the P&ID number DG-1002.
(z)A pipe coupler was observed after air valve (V355) during the walk
around, but was not
drawn on the P&ID number DG-1002.
(aa)A flange was observed below process tank (T307), but was not drawn on
the P&ID
number DG-1002.
(bb)A plastic union was observed on pipeline (PL313-2) after pump (P308),
but was not
drawn on the P&ID number DG-1002.
(cc)A manual valve was observed on pipeline (PL313-2) after pump (P308),
but was not
drawn on the P&ID number DG-1002.
(dd)A second plastic union was observed on pipeline (PL313-2) after pump
(P308)
and a
manual valve (that was not on the drawing), but was not drawn on the P&ID
number
DG-1002.
(ee)A flange was observed on pipeline (PL313-2) after valve (V338), but
was not drawn on
the P&ID number DG-1002.
(ff)A second flange was observed on pipeline (PL313-2) after valve (V338),
but was not
drawn on the P&ID number DG-1002.
(gg)A new line was installed on pipeline (PL305-2) for recycled product to
be sent to 55
gallon drums during the walk around, but was not drawn on the P&ID number
DG-1001.
(hh)Product lines labeled as plastic pipelines PL315-2 and PL313-2 on P&ID
number DG-
1002 were identified in the field as stainless steel product lines.
Employee(s) were exposed to workplace hazards such as, but not limited to
the
detonation of
explosive materials which have historically resulted in death and injury
to persons in and near
the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

2011-09-07 00:00:00

Abate by

2013-11-07 00:00:00

Penalty

Initial $5000.00 · Current $3750.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F):  Process safety information pertaining to the
equipment did not
include the design codes and standards employed:
At the facility, the employer did not include design codes and standards
employed in the process
safety information pertaining to equipment, including, but not limited to
the following:
(a)steel piping
(b)pvc piping
(c)tanks
(d)valves
(e)fittings
Employee(s) were exposed to workplace hazards such as, but not limited to
the detonation of
explosive materials which have historically resulted in death and injury
to persons in and near
the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

2011-09-07 00:00:00

Abate by

2012-01-07 00:00:00

Penalty

Initial $7000.00 · Current $5250.00 Reduced

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:
At the facility, the employer did not document that the relief system
design for pump (P307)
complied with recognized and generally acceptable good engineering
practices.  The employer
did not provide documentation that if the rupture disc for pump (P307) was
to burst, that the
metal fragments traveling at a high velocity and impacting a stainless
steel elbow would not
cause a spark.
Employee(s) were exposed to workplace hazards such as, but not limited to
the detonation of
explosive materials which have historically resulted in death and injury
to persons in and near
the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

2011-09-07 00:00:00

Abate by

2011-09-19 00:00:00

Penalty

Initial $3000.00 · Current $2250.00 Reduced

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:
At the facility, a rupture disc for pump (P307) had not been replaced
annually according to the
manufacturer's recommendation. The manufacturer's recommendation for
changing out the
rupture disc was to prevent premature failure due to corrosion, fatigue,
temperature, or adverse
conditions. The employer did not provide documentation to support
exceeding the manufacturer's
recommendation.
Employee(s) were exposed to workplace hazards such as, but not limited to
the detonation of
explosive materials which have historically resulted in death and injury
to persons in and near
the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

2011-09-07 00:00:00

Abate by

2012-03-05 00:00:00

Penalty

Initial $4000.00 · Current $3000.00 Reduced

General-duty citation text

29 CFR 1910.119(g)(3):  The employer did not prepare a means of verifying
that the employee
had received and understood the training required by 29 CFR 1910.119(g):
At the establishment the company did not document that all employee(s)
including, but not
limited to, operators / mixers working in a covered process (Detagel) had
been provided process
safety management training.
Employee(s) were exposed to workplace hazards such as, but not limited to
the detonation of
explosive materials which have historically resulted in death and injury
to persons in and near
the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

2011-09-07 00:00:00

Abate by

2012-03-05 00:00:00

Penalty

Initial $6000.00 · Current $4500.00 Reduced

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:
At the establishment a written mechanical integrity program addressing
process equipment /
piping operating with deficiencies had not been developed and implemented
for equipment
operating outside acceptable limits such as, but not limited to the
following:
(a)The flexible tubing being used between the aluminum slide gate (V319)
and the ribbon
mixer (RM301).  The flexible tubing had developed holes that allowed
aluminum powder
to escape and after being duct taped, no policy was established to replace
the duct taped
flexible tubing in a timely manner when necessary means are taken to
assure safe
operation.
(b)Employee(s) operating the Filipac machine has been unable to cool the
hydraulic fluid
for the Filipac machine.  The Filipac machine would shut off when the
hydraulic oil
temperature reaches 75 degrees due to the cooling system being unable to
cool the
hydraulic fluid for the past 2 years.
Employee(s) were exposed to workplace hazards such as, but not limited to
the detonation of
explosive materials which have historically resulted in death and injury
to persons in and near
the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

2011-09-07 00:00:00

Abate by

2013-11-07 00:00:00

Penalty

Initial $7000.00 · Current $5250.00 Reduced

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:
Employee(s) working in the Detagel building were exposed to explosion
hazards
due to the
following equipment not receiving mechanical integrity inspections:
(a)there were no mechanical integrity inspection records for the flexible
piping from
the aluminum feeder valve (V319) to the ribbon mixer (RM301) for the past 6
years.
(b)there were no mechanical integrity inspection records for pipe line
PL315-2 (as
indicated on the P&ID, DG-1002) for the past 6 years.
(c)there were no mechanical integrity inspection records for pipe line
PL305-2 (as
indicated on the P&ID, DG-1002) for the past 6 years.
(d)there were no mechanical integrity inspection records for pipe line
SL303-3 for
the past 6 years.
(e)there were no mechanical integrity inspection records for the unlabeled
pipe line
exiting process tank (T306) for the past 6 years.
(f)there were no 2010 general preventive maintenance inspection of tank
(TA103)
(g)there were no thickness testing of tank (TA103)
(h)there were no inside the tank inspection of tank (TA103)
(i)there were no 2010 general preventive maintenance inspection of tank
(TA104)
(j)there were no thickness testing of tank (TA104)
(k)there were no inside the tank inspection of tank (TA104)
(l)there were no 2010 general preventive maintenance inspection of tank
(TA302)
(m)there were no thickness testing of tank (TA302)
(n)there were no inside the tank inspection of tank (TA302)
(o)there were no 2010 general preventive maintenance inspection of tank
(TA303)
(p)there were no thickness testing of tank (TA303)
(q)there were no inside the tank inspection of tank (TA303)
(r)there were no 2010 general preventive maintenance inspection of tank
(TA305)
(s)there were no thickness testing of tank (TA305)
(t)there were no inside the tank inspection of tank (TA305)
(u)there were no 2010 general preventive maintenance inspection of tank
(TA306)
(v)there were no thickness testing of tank (TA306)
(w)there were no inside the tank inspection of tank (TA306)
(x)there were no 2010 general preventive maintenance inspection of tank
(TA307)
(y)there were no thickness testing of tank (TA307)
(z)there were no inside the tank inspection of tank (TA307)
(aa)there were no general preventive maintenance inspection records for
tank (TA308)
(bb)there were no thickness testing records for tank (TA308)
(cc)there were no inside the tank inspection records for tank (TA308)
(dd)there were no general preventive maintenance inspection records for
tank (TA310)
(ee)there were no thickness testing records for tank (TA310)
(ff)there were no inside the tank inspection records for tank (TA310)
Employee(s) were exposed to workplace hazards such as, but not limited to
the detonation of
explosive materials which have historically resulted in death and injury
to persons in and near
the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

2011-09-07 00:00:00

Abate by

2011-12-29 00:00:00

Penalty

Initial $5000.00 · Current $3750.00 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:
Management of change documentation for equipment and piping in the Detagel
building had not
been completed for the following:
(a)No management of change for the temporary repair of the flexible piping
from aluminum
feeder valve (V319) to the ribbon mixer (RM301).  The flexible piping was
wrapped
with duct tape to prevent the aluminum powder from escaping.
(b)No management of change for the attachment of a cloth sleeve to the
rupture disc (#301)
discharge elbow pipe for pump (P307).
(c)No management of change for using nylocks nuts for the re-attachment of
ribbon
mixer
(RM301) paddles.
Employee(s) were exposed to workplace hazards such as, but not limited to
the detonation of
explosive materials which have historically resulted in death and injury
to persons in and near
the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

2011-09-07 00:00:00

Abate by

2013-11-07 00:00:00

Penalty

Initial $5000.00 · Current $3750.00 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 employer did not complete a compliance audit every 3 years to
determine if the procedures
and practices established for the processes covered by the process safety
management standard
were being followed.
Employee(s) were exposed to workplace hazards such as, but not limited to
the detonation of
explosive materials which have historically resulted in death and injury
to persons in and near
the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

2011-09-07 00:00:00

Abate by

2012-09-07 00:00:00

General-duty citation text

29 CFR 1910.119(o)(2):  The compliance audit required by 29 CFR
1910.119(o)(1) was not
conducted by at least one person knowledgeable in the process:
The 2005 compliance audit was conducted without one knowledgeable person
who knew about
the processes at the facility.
Employee(s) were exposed to workplace hazards such as, but not limited to
the detonation of
explosive materials which have historically resulted in death and injury
to persons in and near
the facility.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

2011-09-07 00:00:00

Abate by

2011-09-19 00:00:00

Penalty

Initial $4000.00 · Current $3000.00 Reduced

General-duty citation text

29 CFR 1910.219(d)(1):  Pulley(s) with part(s) seven feet or less from the
floor or work
platform were not guarded in accordance with the requirements specified at
29 CFR
1910.219(m) & (o):
(a)Employee(s) operating the South KP machine in the Detagel packaging
department were
exposed to caught-by hazards due to the cover guard for the mateer's 8
inch and 2 inch
pulleys not being capable of being locked out due to a broken bottom
clasp. The mateer
for the South KP machine operated at 1725 rpms.
(b)Employee(s) operating the North KP machine in the Detagel packaging
department were
exposed to caught-by hazards due to the cover guard for the mateer's 8
inch and 2 inch
pulleys not being capable of being locked out due to the clasp for the
cover not being
locked. The mateer for the North KP machine operated at 1725 rpms.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.

Issued

2011-09-07 00:00:00

Abate by

2011-09-19 00:00:00

General-duty citation text

29 CFR 1910.219(e)(1)(i):  Horizontal belts which had both runs seven feet
or less from the
floor level were not guarded with a guard that extended to at least
fifteen inches above the belt:
(a)Employee(s) operating the South KP machine in the Detagel packaging
department were
exposed to caught-by hazards due to the cover guard for the mateer's
approximately 32
inch belt not being capable of being locked out due to a broken bottom
clasp. The mateer
for the South KP machine operates at 1725 rpms.
(b)Employee(s) operating the North KP machine in the Detagel packaging
department were
exposed to caught-by hazards due to the cover guard for the mateer's
approximately 32
inch belt not being capable of being locked out due to the clasp for the
cover not being
locked. The motor for the mateer for the North KP machine operates at 1725
rpms.
29 CFR 1903.19(d)(1) requires certification and documentation that the
abatement of the
above violation is completed.