OSHA Inspection: SCIENTIFIC PROTEIN LABORATORIES, LLC

Issued

Apr 5, 2012

Abate by

Oct 19, 2012

Penalty

Initial $6,300 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i)(D):     Information concerning the technology of the process did not include safe upper and lower limits for such items as temperatures, pressures, flows or compositions.    The employer did not complete a compilation of written safe upper and lower limits for such items as temperatures, pressures, flows or compositions for the covered processes.    a) Pancreatin manufacturing process.    b) Heparin purification process.    c) Solvent recovery/distillation process.

Issued

Apr 5, 2012

Abate by

Oct 19, 2012

Penalty

Initial $6,300 · Current $6,300

General-duty citation text

29 CFR 1910.119(e)(5):     The employer did not establish a system to promptly address the teams findings and recommendations; did not assure that the recommendations were resolved in a timely manner and that the resolution was documented; did not document what actions were to be taken; did not complete actions as soon as possible; did not develop a written schedule of when these actions were to be completed; did not communicate the actions to operating, maintenance and other employees whose work assignments were in the process and who may have been affected by the recommendations or actions:    After the completion of the Process Hazard Analysis (PHA), the employer did not establish a system to promptly address the teams findings and recommendations; did not assure that the recommendations were resolved in a timely manner and that the resolution was documented; did not document what actions were to be taken; did not complete actions as soon as possible; did not develop a written schedule of when these actions were to be completed; did not communicate the actions to operating, maintenance and other employees whose work assignments were in the process and who may have been affected by the recommendations or actions for PSM covered processes:    a) PHA for the Pancreatin Processes #2 & #3   No resolutions documented, no documentation of what actions are to be taken, no written schedule of when these actions were to be completed.  b) PHA for the Solvent Recovery  No resolutions documented; no documentation of what actions were to be taken, no written schedule of when these actions were to be completed.  c) PHA for the Heparin Renovation  No resolutions documented; no documentation of what actions were to be taken, no written schedule of when these actions were to be completed.  d) PHA for the Building 17  No resolutions documented; no documentation of what actions were to be taken, no written schedule of when those actions were to be completed.

Issued

Apr 5, 2012

Abate by

Oct 19, 2012

Penalty

Initial $6,300 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(i)(2)(iii):     For new facilities, a process hazard analysis had been performed, but recommendations were not resolved or implemented before startup.    The employer did not resolve and implement recommendations from the process hazard analysis for the Building 17 Construction and covered process.    a) Recommendations #42 and #53 - Develop Maintenance & Inspection Procedures.  b) Recommendation #113 - Install high temperature alarm on central alarm system  140 degrees  review design of loop system for design on flow or temperature out or inlet temperature.  c) Recommendation #181 - Standard Operating Procedure for FIT4 removal/replacement   d) Recommendation #182  Standard Operating procedure/PM for strainer removal/replacement   e) Recommendation #26  Ensure there are startup/shutdown procedures.  f) Recommendation #51  Develop pressure test for jacket   g) Recommendation #77  Review training for emergency response for chemical spill

Issued

Apr 5, 2012

Abate by

Oct 19, 2012

Penalty

Initial $6,300 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.119(e)(6):     The employer did not update and revalidate by a team meeting the requirements in paragraph (e)(4) of this section, to assure that the process hazard analysis is consistent with the current process, at least every five (5) years after the completion of the initial process hazard analysis.    The employer did not conduct a process hazard analysis for the Pancreatin 1208 process at least every five years after the completion of the initial process hazard analysis.

Issued

Apr 5, 2012

Abate by

Oct 19, 2012

Penalty

Initial $6,300 · Current $4,410 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(B):     The employer did not develop and implement written operating procedures that provide clear instructions for steps required to correct or avoid deviation from the operating limits in the covered process.    The employer did not develop and implement written operating procedures that provide clear instructions for steps required to correct or avoid deviation from the operating limits in the covered processes:    a) Pancreatin manufacturing process.    b) Heparin purification process.    c) Solvent recovery/distillation process.

Issued

Apr 5, 2012

Abate by

Oct 19, 2012

Penalty

Initial $6,300 · Current $3,150 Reduced

General-duty citation text

29 CFR 1910.119(o)(1):     Employers shall 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 and are being followed.    The employer did not certify that they had evaluated compliance with the provisions of the process safety anagement standard at least every three years for the covered processes.    a) Pancreatin manufacturing process.    b) Heparin purification process.    c) Solvent recovery/distillation process.

Issued

Apr 5, 2012

Penalty

Initial $0 · Current $0

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 this paragraph.    The employer did not develop a written plan of action regarding the implementation of the employee participation for the covered processes.

Issued

Apr 5, 2012

Abate by

Oct 19, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(3):     The employer did not certify that operating procedures were current and accurate.    The employer did not certify that operating procedures were current and accurate to the operation for the covered processes. Operating procedures not certified include, but are not limited to:    a) Procedure 26-0004 Recovery of Ethanol  Still #1.  Last reviewed on 8/18/2008.  b) Procedure 26-0007 Recovery of 87% IPA to 96% IPA on Still #2.  Last reviewed on 1/10/2008.  c) Procedure 26-0019 Receipt of Bulk Virgin IPA into Tank T-1074.  Last reviewed 3/19/2010.  d) Procedure 26-0022 Receipt of Virgin Denatured Ethanol into Tank T-1079. Last review      on 3/19/2010.  e) Procedure 26-0023 Receipt of Virgin IPE into Tank T-1073. Last reviewed on 3/19/2010.  f) Procedure 26-0048 Operation of Peptone Evaporator. Last reviewed on 7/30/2010.