OSHA Inspection: EMERALD PERFORMANCE MATERIALS

Issued

Dec 30, 2011

Abate by

Jan 29, 2012

Penalty

Initial $4,250 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii):     The employer did not document that equipment complied with recognized and generally accepted good engineering practices:    The process safety information for the room pressurization system located in the control room, latex lunchroom, second floor motor control center and the latex engine room did not list the applicable engineering standard which is applied so as to prevent intrusion of flammable vapors in these areas where general duty electrical equipment is in use.    .

Issued

Dec 30, 2011

Abate by

Feb 28, 2012

Penalty

Initial $7,000 · Current $4,900 Reduced

General-duty citation text

29 CFR 1910.119(e)(1):     The process hazard analysis was not appropriate to the complexity of the process and did not identify, evaluate, and address the control of the hazards involved in the process:    The process hazard analysis (PHA) done in 2007 for reactor 29 and 30, and in prior years, mentioned the possibility of hydrostatically overfilling the reactors in the Latex process and lists high pressure alarms as one means to prevent this from occurring.  This was not appropriate because the unexpectedly rapid rise in pressure due to a pressure produced by a relatively incompressible liquid, as opposed to gas pressure rise, precludes any action by the operator in response to an alarm.

Issued

Dec 30, 2011

Abate by

Feb 28, 2012

Penalty

Initial $4,250 · Current $2,975 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(v):     The process hazard analysis did not address the hazards of facility siting:    1.  The PHA done in 2007 and in prior years did not address the control room location near the Latex processing equipment.    2.  The PHA done in 2007 and in prior years did not address the location of the round sump diversion tank which is near the area where a tank semi trailer is brought in and stored; the possibility of a vehicle strike was not addressed in the PHA.

Issued

Dec 30, 2011

Abate by

Jan 29, 2012

Penalty

Initial $4,250 · Current $2,975 Reduced

General-duty citation text

29 CFR 1910.1051(d)(1)(iii):     No short term exposure limit (STEL) monitoring was done on the basis of one or more samples representing 15-minute exposures associated with operations that are most likely to produce exposures above the STEL for each shift and for each job classification in each work area.    No STEL samples were collected, only full shift 8-hour sampling was done.

Issued

Dec 30, 2011

Abate by

Jan 29, 2012

Penalty

Initial $4,250 · Current $2,975 Reduced

General-duty citation text

29 CFR 1910.1051(f)(2)(i):     Where any exposures are over the PELs, the employer failed to establish and implement a written plan to reduce employee exposure to or below the PELs primarily by engineering and work practice controls:    Although exposures in excess of the PEL were found in 2009 and 2010, no written exposure control plan was developed and implemented.

Issued

Dec 30, 2011

Abate by

Jan 29, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1051(g)(1):     For those operations and job classifications where employee exposure are greater then the action level, the employer failed to have an exposure goal program which includes all the items listed in 29 CFR 1910.1051(g)(5)(i) through (vi):    Although exposures in excess of the action level were found in 2009 and 2010, no written exposure goal program was developed and implemented.

Issued

Dec 30, 2011

Abate by

Jan 29, 2012

Penalty

Initial $4,250 · Current $2,975 Reduced

General-duty citation text

29 CFR 1910.1051(m)(2)(ii)(B):     The employer did not establish and maintain an accurate record of all exposure measurements taken to monitor employee exposure to Butadiene (BD), which included the operation involving exposure to BD, which is being monitored:    Exposure monitoring records done in  2009 and 2010 did not include the areas employees were working and what work they were doing.

Issued

Dec 30, 2011

Abate by

Feb 14, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1051(m)(2)(ii)(E):     The employer did not establish and maintain an accurate record of all exposure measurements taken to monitor employee exposure to Butadiene, which included the type of protective devices worn, if any:    Exposure monitoring records done in 2009 and 2010 did not include any information on respiratory protection or other personal protective equipment worn.

Issued

Dec 30, 2011

Abate by

Jan 29, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1051(m)(2)(ii)(G):     The employer did not establish and maintain an accurate record of all exposure measurements taken to monitor employee exposure to Butadiene, which included written corrective action and the schedule for completion of this action:    Exposure monitoring records done in 2009 and 2010 did not include any information on proposed corrective actions and schedule.