OSHA Inspection: CONTINENTAL CARBONIC PRODUCTS, INC.

Issued

Jul 19, 2012

Abate by

Aug 30, 2012

Penalty

Initial $3,825 · Current $500 Reduced

General-duty citation text

29 CFR 1910.38(c):     Minimum elements of an emergency action plan. An emergency action plan must include at a minimum:    The employer did not ensure that the emergency action plan as required by 1910.119 contained the following procedures:    a) Procedures for reporting a fire or other emergency;  b) Procedures for emergency evacuation including the type of evacuation and exit route assignments;  c) Procedures to be followed by employees who remain to operate critical plant operations before they evacuate.

Issued

Jul 19, 2012

Abate by

Aug 30, 2012

Penalty

Initial $3,825 · Current $1,900 Reduced

General-duty citation text

29 CFR 1910.151(c):     Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.      The employer did not ensure that an emergency shower was available for employees working with ammonia (corrosive) in that no emergency shower had been installed.

Issued

Jul 19, 2012

Abate by

Aug 30, 2012

Penalty

Initial $3,825 · Current $1,900 Reduced

General-duty citation text

29 CFR 1910.119(e)(5):     The employer shall establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.    The employer did not establish a system to address the team's findings and recommendations in that a process hazard analysis was conducted on April 28, 2011 and 93 recommendations were identified. The company provided no documentation that the recommendations had been addressed other than 5 unidentified photos.

Issued

Jul 19, 2012

Abate by

Aug 30, 2012

Penalty

Initial $3,825 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(D):     Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner.    The employer did not ensure that emergency shutdown procedures included the responsibility of emergency shutdown.

Issued

Jul 19, 2012

Abate by

Aug 30, 2012

Penalty

Initial $3,825 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(g)(1)(i):     Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks.    The employer did not ensure that employees assigned to operate the Skid which contained 22,000 pounds of ammonia were trained on the standard operating procedures and emergency operations including emergency shutdown procedures.

Issued

Jul 19, 2012

Abate by

Aug 30, 2012

Penalty

Initial $3,825 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(g)(3):     Training documentation. The employer shall ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The employer shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.    The employer did not ensure that employees were given a means to verity that the training was understood in that no type of evaluation was conducted.

Issued

Jul 19, 2012

Abate by

Dec 31, 2012

Penalty

Initial $3,825 · Current $3,825

General-duty citation text

29 CFR 1910.119(j)(2):     Written procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment.    The employer did not ensure that written procedures for mechanical integrity of process equipment was adequate in that:    a) The employer had developed a written procedure for checking the ammonia sensors quarterly but the employer did not include the steps needed to perform the task or the amount of ammmonia (parts per million) to be used to perform the task;    b) The employer had developed written procedures for preventative maintenance tasks for the pressure vessels, heat exchanger, compressors and condenser but the procedures did not include the steps to complete the tasks and what was acceptable criteria for the equipment.

Issued

Jul 19, 2012

Abate by

Aug 30, 2012

Penalty

Initial $3,825 · Current $1,900 Reduced

General-duty citation text

29 CFR 1910.119(j)(3):     Training for process maintenance activities. The employer shall train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner.    The employer did not ensure that maintenance technicians whose job duties include maintaining the ongoing integrity of the process equipment had been trained on the procedures.

Issued

Jul 19, 2012

Abate by

Aug 30, 2012

Penalty

Initial $3,825 · Current $500 Reduced

General-duty citation text

29 CFR 1910.119(l)(1):     The employer shall establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.    The employer did not implement adequate management of change (MOC) procedures in that on or about July 2011 a management of change occurred to increase the size of valve E-7 and the plant manager did not sign off on the MOC only the corporate engineer signed off.

Issued

Jul 19, 2012

Abate by

Aug 30, 2012

Penalty

Initial $3,825 · Current $1,900 Reduced

General-duty citation text

29 CFR 1910.119(n):     Emergency planning and response. The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan shall include procedures for handling small releases. Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120 (a), (p) and (q).    The employer did not ensure that the emergency action plan included procedures for handling small releases. The Skid has 22,000 pounds of ammonia.