OSHA Inspection: BOSTIK, INC.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

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:
(a) Location - Direct Solvation, Building 9:
On or about the time of the Inspection, the process safety information
(PSI) pertaining
to the equipment in the process did not include documentation that
equipment, including
but not limited to valves, electrical wiring and safety systems such as
interlocks and
suppression systems, complied with recognized and generally accepted good
engineering
practices (RAGAGEP).

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000 · Current $6,500 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i):  The process hazard analysis did not address the
hazards of the
process:
(a) Location - Direct Solvation - Building 9:
On or about the time of the Inspection, the process hazard analysis (PHA)
did not fully
identify the hazards of power failure.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000

General-duty citation text

29 CFR 1910.119(e)(3)(ii):  The process hazard analysis did not identify
any previous incident
which had a likely potential for catastrophic consequencces in the
workplace:
(a) Location - Direct Solvation - Building 9:
On or about the time of the Inspection, the process hazard analysis (PHA)
did not
identify the following incidents:
1.  In March 2009, a rupture disk blew resulting in a 1,000 pound spill of
MEK,
toluene, and polyester resin.
2.  In March 2009, a rupture disk blew resulting in a 15 gallon spill of
MEK.
3.  In April 2009, an over-pressurization in the Solvator resulted in a
spill of MEK.
4.  In October 2009, a power outage occurred at the facility resulting in
fires in the
freezer pumps.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000 · Current $6,500 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(iii):  The process hazard analysis did not address
the engineering and
administrative controls applicable to the hazards and their
interrelationship, such as, appropriate
of detection methodologies to provide early warning of releases:
(a) Location irect Solvation uilding 9:
On or about the time of the Inspection, the employers process hazard
analysis did not
identify adequate safeguards to control high consequence hazards.  For
example, the
employer chose to address the potential of leaving valves in the wrong
position with
administrative controls (such as training and procedures) in order to
prevent catastrophic
hazards.  Engineering controls were feasible and should have been used.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000 · Current $6,500 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:
(a) Location - Direct Solvation - Building 9:
On or about the time of the Inspection, the employer did not fully address
team findings
and recommendations in the Solvator process hazard analysis (PHA) in a
timely manner
or that the resolution was documented and closed:
1) The recommendation for verifying that the pressure relief valves were
in
place and
what the valve was rated for;
2) The recommendation that a check valve be installed to prevent back flow
when adding
flammable liquids to the Solvator;
3) The recommendation to upgrade the Solvator cooling system;
4) The recommendation to automate pressure control for Nitrogen; and
5) The recommendation to add relief valve in filter housing to vent back
to Solvator.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000 · Current $6,500 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) through (f)(1)(iv):
(a) Location - Direct Solvation:
On or about the time of the Inspection, operating procedures were not
developed and
implemented to address communication and other activities involving shift
changes.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000 · Current $6,500 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(C):  The employer's written operating procedures
covering the steps
for each operating phase did not address temporary operations:
(a) Location - Direct Solvation, Building 9:
On or about the time of the Inspection, the written operating procedure,
DS-028; Rev:
2-Breaking Vacuum on R8, did not provide procedures for operating the
backup vacuum
pumps.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000

General-duty citation text

29 CFR 1910.119(f)(1)(i)(E):  The employer's written operating procedures
covering the steps
for each operating phase did not address emergency operations:
(a) Location - Direct Solvation, Building 9:
On or about the time of the Inspection, the written operating procedure,
DS-028; Rev:
2-Breaking Vacuum on R8, did not fully outline the specific steps to be
performed to
stop the process in the event of an emergency.
(b) Location - Direct Solvation, Building 9:
On or about the time of the inspection, the written operating procedure,
DS-011; Rev:
2 Transfer of Resin from R8 to Solvator did not fully describe certain
symptoms that
would indicate a potential emergency condition or fully address methods of
investigation
if one of these symptoms is observed.  Further, the company did not have a
separate
operating procedure to describe what to do in the event that a potential
flammable
mixture has been released into the facility.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(A):  The employer's written operating procedures
covering the
operating limits did not address consequences of deviation beyond such
operating limits:
(a) Location - Direct Solvation, Building 9:
On or about the time of the Inspection, the written operating procedure,
DS-028; Rev:
2-Breaking Vacuum on R8, did not fully address consequences of deviation
beyond
operating limits.
(b) Location - Direct Solvation, Building 9:
On or about the time of the Inspection, the written operating procedure
DS-011; Rev:2 -
Transfer of Resin from R8 to Solvator, did not fully address consequences
of mixing of
high temperature product with solvent in the solvator.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(B):  The employer's written operating procedures
covering the
operating limits did not address the steps required to correct or avoid
deviation
beyond such
operating limits:
(a) Location - Direct Solvation, Building 9:
On or about the time of the Inspection, the written operating procedure,
DS-028; Rev:
2-Breaking Vacuum on R8, did not fully address the steps required to
correct or avoid
deviation beyond operating limits.
(b) Location - Direct Solvation, Building 9:
On or about the time of the Inspection, the written operating procedure
DS-011; Rev:2 -
Transfer of Resin from R8 to Solvator, did not fully address the steps
required to correct
or avoid mixing high temperature product with solvent in the solvator.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000 · Current $6,500 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:
(a) Location - Direct Solvation - Building 9:
On or about the time of the Inspection, the employer did not inform
electrical contract
employees working on or near a covered process of the known fire and
explosion
hazards.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000 · Current $6,500 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:
(a) Location - Direct Solvation - Building 9:
On or about the time of the Inspection, the company did not have a written
mechanical
integrity program that addressed the preventive maintenance, inspection
and testing for
pumps.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000 · Current $6,500 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iii):  The frequency of inspections and tests of
process equipment to
maintain its mechanical integrity, was not consistent with applicable
manufacturers'
recommendations and good engineering practices, or more frequently
determined to be necessary
by prior operating experience:
(a) Location - Direct Solvation, Building 9:
On or about the time of the Inspection, inspection and testing frequency
of the process
vapor ventilation system was not frequent enough to prevent clogging of
vapor system
components due to excessive buildup of vapor condensate.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000 · Current $6,500 Reduced

General-duty citation text

29 CFR 1910.119(j)(5):  The employer did not correct deficiencies in
equipment that were
outside acceptable limits (as defined by process information in 29 CFR
1910.119(d) before
further use or in a safe and timely manner:
(a) Location - Direct Solvation uilding 9:
On or about the time of the Inspection, the employer did not fully correct
deficiencies
on process equipment before further use or in a timely manner. Uncorrected
deficiencies
that were noted in mechanical integrity inspections and had not been
corrected include
but are not limited to corrosion on process vessels, leaks under or
through insulation on
process vessels, leaks on flanges, and leaks in plugs.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000 · Current $6,500 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:
(a) Location - Direct Solvation, Building 9:
On or about the time of the Inspection, the employer did not effectively
implement
the
change of two manually controlled valves with an air actuated valve.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000 · Current $6,500 Reduced

General-duty citation text

29 CFR 1910.119(l)(4):  A change covered by 29 CFR 1910.119(l) resulted in
a change in the
process safety information required by 29 CFR 1910.119(d) and the process
information was not
updated:
(a) Location - Direct Solvation, Building 9:
On or about the time of Inspection, the piping & instrument diagrams
(P&ID) for the
solvator did not reflect the replacement of two manual valves with a
single air actuated
valve/transfer valve.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000 · Current $6,500 Reduced

General-duty citation text

29 CFR 1910.119(l)(5):  A change covered 29 CFR 1910.119(l) resulted in a
change in the
operating procedures or practices required by 29 CFR 1910.119(f), and such
procedures or
practices were not updated:
(a) Location - Direct Solvation, Building 9:
On or about the time of the Inspection, the operating procedure DS-011;
Rev: 2 -
Transfer of Resin from R8 to Solvator, did not reflect the replacement of
two manual
valves referenced in the procedure with a single air actuated
valve/transfer valve.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000 · Current $6,500 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:
(a) Location - Direct Solvation - Building 9:
On or about the time of the Inspection, the employer did not conduct an
investigation of
an incident that occurred prior to the explosion in which solvent was
added to high
temperature product in the Solvator prior to cooling resulting in a vapor
release of
polyester distillate.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000

General-duty citation text

29 CFR 1910.119(m)(5):  The employer did not establish a system to
promptly address and
resolve the incident investigation report findings and recommendations:
(a) Location - Direct Solvation, Building 9:
On or about the time of the Inspection, recommendations made to resolve
findings
resulting from an incident investigation conducted on 10/24/2008, which
involved a vapor
release due to clogged vent lines, had not been resolved.
(b) Location - Polyurethane:
On or about the time of the Inspection, recommendations made to resolve
findings
resulting from an incident investigation conducted on 09/13/2010, which
involved over
pressurization of a vessel due to a plugged flame arrestor, had not been
resolved.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $7,000 · Current $6,500 Reduced

General-duty citation text

29 CFR 1910.178(l)(3)(ii)(F)
Powered industrial truck operators did not receive initial training in the
workplace related topic
of Hazardous (classified) locations where the vehicle will be operated.
(a) Location - Direct Solvation - Building 9:
On or about the time of the Inspection, the employer did not train their
powered
industrial truck operators on the hazards of operating in a classified
location.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $70,000 · Current $69,500 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i):  Process safety information (PSI) pertaining to
the equipment in the
process did not include the elements specified in 29 CFR
1910.119(d)(3)(i)(A) through (H):
(a) Location - Direct Solvation, Building 9:
On or about the time of the Inspection, certain process safety information
(PSI)
pertaining to the equipment in the process was not adequate; examples
include but are
not limited to:
1) PSI for the emergency relief systems was missing elements such as but
not limited to
design codes and upset scenarios.
2) PSI for the process vapor capture system was missing elements such as
but not limited
to design codes, materials of construction, and limitations of the system.
3) PSI for piping/pumps was missing elements such as but not limited to
materials of
construction, pump curves and compatibilities between the pumps and
piping.
4) PSI for flexible hoses was not available.
5) The PSI related to ventilation system design was missing elements such
as but not
limited to the volume of the process areas, surface area of exhaust vents,
the number of
air changes per hour and did not identify the areas where the exhaust
system discharged.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $70,000 · Current $70,000

General-duty citation text

29 CFR 1910.119(e)(3)(ii):  The process hazard analysis did not identify
previous incidents
which had a likely potential for catastrophic consequencces in the
workplace:
(a) Location - Direct Solvation - Building 9, Solvent Cement - Building 24
and Polyester
- Building 36:
On or about the time of the Inspection, the process hazard analysis (PHA)
did not
address the following incidents to control impacts to process equipment
from powered
industrial vehicles including damage to ventilation trunks, storage racks,
water lines and
electrical equipment.
1) In Direct Solvation on 11/4/09, a ventilation trunk was struck by a
tote being lifted
by a forklift.
2) In Solvent Cement on 11/2/09 a forklift struck a storage rack.
3) In Polyester Building 36, on 4/27/09, a forklift struck a water line
causing it to
rupture and also damaged an electrical box.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $70,000

General-duty citation text

29 CFR 1910.119(e)(3)(vi):  The process hazard analysis did not address
human factors:
(a) Location - Direct Solvation, Building 9:
On or about the time of the Inspection, the process hazard analysis did
not fully address
human factors including, but not limited to, shift changes for operators,
critical alarms
or sounds, and excessive overtime.

Issued

Sep 12, 2011

Abate by

Apr 19, 2012

Penalty

Initial $70,000 · Current $69,500 Reduced

General-duty citation text

29 CFR 1910.178(m)(11): Only approved industrial trucks were not used used
in hazardous
locations.
(a) Location - Direct Solvation - Building 9:
On or about the time of the Inspection, three electric powered industrial
trucks designated
as "E" were used in Class I hazardous locations.