OSHA Inspection: GLOBAL PYROTECHNIC SOLUTIONS, INC.

Issued

Sep 4, 2012

Abate by

Dec 3, 2012

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.106(d)(4)(i):   Inside storage rooms were not constructed to meet the required fire-resistive rating for their use. Such construction did not comply with the test specifications set forth in Standard Methods of Fire Tests of Building Construction and Materials, NFPA 251-1969.  Openings to other rooms or buildings were not provided with noncombustible liquid-tight raised sills or ramps at least 4 inches in height, or the floor in the storage area was not at least 4 inches below the surrounding floor. Openings were not provided with approved self-closing fire doors.    At the time of the inspection, chemical storage room #6 used to store flammables was not equipped with an approved self closing door or provided with liquid-tight raised sills.

Issued

Sep 4, 2012

Abate by

Dec 3, 2012

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.106(d)(4)(iv):  Inside storage room was not be provided with either a gravity or a mechanical exhaust ventilation system. Such system shall be designed to provide for a complete change of air within the room at least six times per hour.     At the time of the inspection, chemical storage room #6 was used to store and dispense flammables and was not provided with a ventilation system to provide a complete air change 6 times per hour as required.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $4,900 · Current $0 Reduced

General-duty citation text

29 CFR 1910.109(b)(1):  Explosives or blasting agents were stored, handled, and/or transported when such storage, handling, and transporting of  such explosives or blasting agents constituted an undue hazard to life:    At the time of the inspection, the employer violated this section of the standard by exposing all workers to explosion hazards and did not comply with consensus standard NFPA 1124 the following sections;    a) 4.3.1.1 Manufacturers shall maintain records in compliance with federal  regulations. The employer had no records of inspections of equipment such as the bonding and grounding tests for mechanical equipment.  b) 4.5.1.2 Wall joints and openings for wiring, plumbing, and other utilities shall be  sealed to prevent the entry of dusts. The inspection found openings in process buildings that could allow entry of dust.  c) 4.5.3.4.2 All presses and other such mechanical devices used in the vicinity of  exposed explosive or pyrotechnic composition shall be electrically bonded and  grounded. The inspection found no record that mechanical equipment such as the Stokes press was electrically bonded and grounded.  d) 4.12.1.1 All buildings shall be kept clean and orderly, and dust and rubbish shall  be kept to a minimum. The inspection found accumulations of trash inside process buildings.  e) 4.12.1.5 Rags, combustible scrap and paper shall be kept in approved, marked  containers until removed from the building. The inspection found accumulations of trash inside of process buildings.  f) 4.12.4.1 Personnel working at or supervising mixing, pressing, and loading  operations shall be provided with and shall wear cotton or other similarly  protective clothing. The inspection found multiple instances where employees were wearing clothing that was not 100% cotton.  g) 4.13.2.2 An emergency warning signal shall be established. The inspection found that no emergency warning signal was in place.  h) 4.15.1 The number of occupants in each process building and in each magazine  shall not exceed the number necessary to conduct production operations. The inspection found that the number of employees needed in process buildings exceeded the number necessary to conduct operations at the time of the composition flash.  i) 4.15.2 The maximum number of occupants and maximum weight of pyrotechnic  and explosive composition permitted in each process building and in each  magazine shall be posted in a conspicuous location in each process building or  magazine. The inspection did not find occupancy or weight limits posted in process buildings.  j) 5.3.1 The following shall not be permitted inside of or within 50 ft (15 m) of a  magazine: (4) Spark-producing devices. The inspection found multiple instances on spark producing tools inside process buildings.  k) 5.7.10 Tools and equipment shall be made of or covered with non-sparkproducing  materials. The tools found inside process buildings were not made of non-spark producing materials.  l) 6.8.3.3 Exit doors shall be equipped with panic hardware. The inspection found that some process building doors were not equipped with panic hardware.  m) 6.11.6 Signs that read as follows in letters not less than 4 in. (102 mm) high on a  contrasting background shall be conspicuously posted on the outside of any  consumer fireworks storage building: FIREWORKS  NO SMOKING The inspection found that process buildings were not posted with proper no smoking signs.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(iii): The Process Hazard Analysis(PHA) did not address engineering and administrative controls applicable to the hazards.    At the time of the inspection, the PHA for the covered process of manufacturing incendiary pellets did not address engineering controls that were implemented. The Press 1 Building PHA, Dated 4/1/2010 (Doc-4), did not address that the employer has installed grounding rods, pads and cables throughout Press 1 Building. Items including, but not limited to, functional testing of grounding rods, functional testing of grounding cables and pads, and ensuring  components are properly grounded were not reviewed.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(iv):  The Process Hazard Analysis(PHA) did not address the consequences of failure of engineering and administrative controls;    At the time of the inspection, the employer PHAs did not address the failure of engineering and/or administrative controls. In the press room, work buildings #5A,B,C, and D, Mix Bay, and dryers engineering and administrative controls were used to control hazards but no review was made in the related PHAs.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(v):  The Process Hazard AnalysisPHA did not address facility siting;    At the time of the inspection, the PHA did not fully address facility siting including, but not limited to, the  assessment of distances from onsite roadways, vehicle traffic up to work  buildings, vehicles parking too close to a work building, vehicles potentially hitting  a work building, and the introduction of potential ignition sources (lawn mower,  weed trimmer, snow plow, chainsaws, tractors).

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The Process Hazard Analysis(PHA) did not address human factors;    At the time of the inspection, the employer conducted PHAs for covered processes but did not include a review of hazards of human factors. The PHA "checklist" did not have any questions to evaluate human factor hazards.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(vii):  The Process Hazard Analysis(PHA) did not address qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace.    At the time of the inspection, the PHA did not fully address and include an evaluation of a range of the  possible safety and health effects of failure of controls on employees in the workplace including, but not limited to, exposure to energetic materials in powdered form, chemical exposures, AM/FM radios being present inside or near  classified areas, and not following written procedures.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(4): The Process Hazard Analysis(PHA) was not performed by a team with expertise in engineering and process operations, and the team did not include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team was not knowledgeable in the specific process hazard analysis methodology being used.    At the time of the inspection, the Work Building #5-D PHA, Dated 4/1/2010 (Doc-4), was completed by a single individual and not a team with expertise in engineering and process operations. As noted on the summary heading, Hazard Analysis Team Members provides a single signature. A printed signature of the Safety Director exists on the form but is not identified as being part of the PHA team.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $4,900 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(1):  The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information during normal operation.    At the time of the inspection, the normal operation procedures did not address the operation of the ventilation system in press buildings, mix bay, dryers,and work buildings.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $4,900 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i): The employer did not develop and implement written operating procedures for emergency shutdown and operation;    At the time of the inspection, the employee had not included emergency shutdown and emergency operations  requirements in the operating procedures for processes covered under process safety management.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $4,900 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(i)(1): The employer did not perform a pre-startup safety review(PSSR) for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.    At the time of the inspection, it was found that the employer had not conducted a PSSR for the new process of producing incendiery pellets in Press Room 1B.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $4,900 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(3):  The employer did not train employees involved in maintaining the on-going integrity of process equipment in an overview of the inspection process and the procedures required to perform the employee's job tasks.    At the time of the inspection, the employer had not trained employees on how to maintain process equipment used in PSM covered processes. Specifically, no employees were trained in what maintenance actvities were required to keep the Stokes Tablet press in safe operating condition.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(m)(2):  An incident investigation was not initiated as promptly as possible, but not later than 48 hours following the incident.    At the time of the inspection, it was found that a flash/explosion had occurred near warehouse 4 and no incident investigation had been initiated.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $4,900 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(o)(1):  Employers did not verify that the procedures and practices developed under the standard were adequate:    At the time of the inspection, the employer had not conducted an audit of all 14 elements of the PSM program to verify that it was effective in controlling the hazards of the covered processes, manufacturing fireworks and incendiary pellets. Audit must be completed every 3 years.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $4,900 · Current $0 Reduced

General-duty citation text

29 CFR 1910.217(f)(2):  Operatorswere not trained and instructed in the safe method of work before starting work on mechanical power press:    At the time of the inspection, employees operating the Stokes Tablet mechanical power press to produce incendiary pellets had not been trained in the safe operation of the press.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.109(c)(2)(iii):  Property upon which Class I magazines are located and property where Class II magazines are located outside of buildings were not posted with signs reading "Explosives-Keep Off."    At the time of the inspection, shipping containers used as magazines were not posted with warning signs. No method was used to identify the hazard in each container.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.109(d)(2)(i):  Vehicles used for transporting explosives shall be strong enough to carry the load without difficulty and be in good mechanical condition. If vehicles do not have a closed body, the body shall be covered with a flameproof and moistureproof tarpaulin or other effective protection against moisture and sparks. All vehicles used for the transportation of explosives shall have tight floors and any exposed spark-producing metal on the inside of the body shall be covered with wood or other nonsparking materials to prevent contact with packages of explosives. Packages of explosives shall not be loaded above the sides of an open-body vehicle.    At the time of the inspection, trucks used to transport explosives on the company property were not equipped to protect explosives from the hazards of moisture and/or sparks.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.109(d)(2)(ii)(a):  Exterior markings or placards required on applicable vehicles were not as follows for the various classes of commodities:  _________________________________________________________________                                                     Commodity                 Type of marking or placard  ____________________________________ ____________________________                                         Explosives, Class A, any quantity     Explosives A (Red letters   or a combination of Class A and        on white background).   Class B explosives.                   Explosives, Class B, and quantity.    Explosives B (Red letters                                          on white background).  Oxidizing material (blasting          Oxidizers (Yellow letters   agents, ammonium nitrate, etc.),       on black background).   1,000 pounds or more gross             weight.                               ____________________________________ ____________________________    At the time of the inspection, pickup trucls used to trasport explosives within the facility were not equipped with signs to identify the hazardous materials being transported.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $0 · Current $0

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.    At the time of the inspection, the employer did not properly control replacement parts. Replacement parts such a dies for the Stokes Tablet press were not part of a process to ensure that they were compatible for the use in manufacture of the incendiary pellets.

Issued

Sep 4, 2012

Abate by

Sep 19, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(d)(1)(ii):  The employer did not select and use a NIOSH-certified respirator in compliance with the conditions of its certification:    At the time of the inspection, the employer supplied a nuisance dust mask that was not Niosh approved. The MCR safety model RPDM1 was supplied to employees working in Press room #1 and the box stated "Does not provide NIOSH approved respiratory protection.