OSHA Inspection: ELEMENTIS SPECIALTIES

Issued

Jul 17, 2012

Penalty

Initial $4,250 · Current $3,400 Reduced

General-duty citation text

29 CFR 1910.22(a)(1):     All places of employment, passageways, storerooms or service rooms were not kept clean and orderly or in a sanitary condition:    a. In the Betone packing area, combustible dust had accumulated on surfaces, including building structure surfaces, piping, conduit, equipment support; dust levels were measured at depths greater than 1/8 inch; a housekeeping program had not been established to control dust accumulation.  (Note: an example standard for acceptable dust accumulation is NFPA 654.)

Issued

Jul 17, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.307(c):     Equipment, wiring methods, and installations of equipment in hazardous (classified) locations were not intrinsically safe, approved for the hazardous (classified) location, or safe for the hazardous (classified) location:    a. In the Betone packing area, combustible dust had accumulated on surfaces, including building structure surfaces, piping, conduit, equipment support, where there were examples of general electrical wiring and equipment; dust levels were measured at depths greater than 1/8 inch; a housekeeping program had not been established to control dust accumulation.  (Note: upon the establishment of a housekeeping program that controls dust, such as explained in NFPA 654, electrical wiring and equipment for a hazardous location is not required.)

Issued

Jul 17, 2012

Abate by

Sep 19, 2012

Penalty

Initial $4,250 · Current $3,400 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B):     The employer's piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process:    a. Not all equipment was included on P&ID's or was not accurate, such as, but not limited to, valve V0208 (Drawing 143-D102) was not present on the TDI line.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jul 17, 2012

Abate by

Mar 19, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(2):     The employer did not implement written procedures to maintain the on-going integrity of process equipment    a. Equipment was not labeled as required by company procedures with specific identifying numbers (MI001, 3.1, 7.1, 7.2; MI020, 5.1.3), such as, but not limited to, manual valve V0232.  (Note: at the time of the inspection equipment was in the process of being identified and labeled, but much of the equipment was not labeled.)    b. Not all equipment was inspected as required by company procedures to ensure mechanical integrity of equipment, such as pressure relief PSV-309 (set at 325 psi, for system pressure of 300 psi).    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jul 17, 2012

Penalty

Initial $4,250 · Current $2,125 Reduced

General-duty citation text

29 CFR 1910.119(f)(3):     The employer did not annually certify that operating procedures were current and accurate:    a. Operating procedures had not been certified annually.

Issued

Jul 17, 2012

Abate by

Sep 19, 2012

Penalty

Initial $4,250 · Current $3,400 Reduced

General-duty citation text

29 CFR 1910.119(g)(1)(i):     The employer did not train each employee in an overview of the process:    a. Not all employees (including operators and maintenance) were trained on the process safety management overview and hazards associated with the process.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jul 17, 2012

Abate by

Mar 19, 2013

Penalty

Initial $4,250 · Current $3,400 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i):     The employer did not perform inspection and tests on process equipment:    a. There was no inspection on equipment such as, PSV-309 and internal integrity of reactor vessels.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jul 17, 2012

Abate by

Mar 19, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(iii):     The frequency of inspections and tests of process equipment were not consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience:    a. There was no inspection on equipment such as, the internal reactor vessels, and inspection frequency was deficient in identifying the dismantled actuator valve FV301-4 or proper relief for PSV-309.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jul 17, 2012

Abate by

Mar 19, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(iv):     The employer did not document each inspection and test that was performed on process equipment:     a. There was no inspection documentation on all valves, such as, but not limited to, PSV-309 and FV301-4.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jul 17, 2012

Abate by

Sep 19, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5):     The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information on paragraph (d) of this section):    a. During the inspection, there were examples of valves that were not functioning as designed or were not set to provide designed protection, such as FV301-4 and PSV-309.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).