OSHA Inspection: GERDAU SPECIAL STEEL NORTH AMERICA

Issued

Sep 28, 2012

Abate by

Jan 15, 2013

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.119(e)(1):     The process hazard analysis did not identify, evaluate, and address the control of the hazards involved in the process:    (a) The process hazard analysis did not address heat treat furnaces, nitrogen supply/purge system, natural gas supply system and confined spaces.

Issued

Sep 28, 2012

Abate by

Jan 15, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(4):     The employer did not develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel:    (a) A procedure was not developed to control entrance, presence and exit of contract employers and contract employees that work on or around process safety management covered processes.

Issued

Sep 28, 2012

Abate by

Jan 15, 2013

Penalty

Initial $3,000 · Current $0 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) Employees who operate an anhydrous ammonia covered process, or have work duties associated with the covered process, were not trained in an overview of the processes. Employees were not familiar with the following aspects of process safety management (PSM):    1. What process safety management is.  2. Processes covered under process safety management.  3. Employee responsibilities and involvement regarding process safety management.

Issued

Sep 28, 2012

Abate by

Jan 15, 2013

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.119(j)(2):     The employer did not establish or implement written procedures to maintain the on-going integrity of process equipment    (a) The company did not develop written procedures that outline process equipment covered under mechanical integrity, what the inspection and testing requirements for covered equipment are, and the personnel responsible for ensuring inspection and testing requirements are maintained.

Issued

Sep 28, 2012

Abate by

Jan 15, 2013

Penalty

Initial $3,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(n):     The employer did not establish an emergency plan for the entire plant in accordance with the provisions of 29 CFR 1910.38:    (a) The emergency action plan did not identify procedures to be taken when the emergency involves a release of ammonia. The procedures not identified are, a safe evacuation point according to wind sock direction and procedure to shut down the ammonia system when evacuation of the facility is initiated.

Issued

Sep 28, 2012

Abate by

Jan 15, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.38(c):     The employer did not implement an emergency action plan which included at a minimum the elements required by paragraphs 1910.38(c)(1)-(6) of this part:    (a) The emergency action plan did not identify procedures to be taken when the emergency involves a release of ammonia. The procedures not developed are safe evacuation point according to wind sock direction and a procedure for employees who remain to to shut down the ammonia system when evacuation of the facility is initiated.

Issued

Sep 28, 2012

Abate by

Nov 30, 2012

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.146(d)(4)(i):     Under the permit-required confined space program required by 29 CFR 1910.146(c)(4), the employer did not provide, at no cost to the employees, testing and monitoring equipment needed to comply with 29 CFR 1910.146(d)(5):    (a) During entry into permit-required confined space(s), such as furnace pits, workers were potentially exposed to anhydrous ammonia which was utilized in the heat treating process.  However, no air monitoring equipment or monitoring device was provided to alert both entrants and attendant(s) whether permissible entry concentrations of anhydrous ammonia were exceeded.

Issued

Sep 28, 2012

Abate by

Nov 30, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.146(f)(10):     The entry permit that documented compliance and authorized entry to a permit space did not identify the results of initial and periodic tests performed under 29 CFR 1910.146(d)(5), accompanied by the names or initials of the tester:    (a)  Periodically entries (such as entries performed on 2/12, 3/23/12, and 4/16/12) have been made into permit-required confined spaces, such as furnace pits.  However, entry permits have not been adequately completed.  For example, these entry permits did not include initial and periodic gas meter readings for flammable gases (% LEL or % LFL) and for toxic gases (carbon monoxide and ammonia).

Issued

Sep 28, 2012

Abate by

Nov 13, 2012

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.147(c)(6)(i):     The employer did not conduct an annual or more frequent inspection of the energy control procedure to ensure that the procedure and requirements of this standard were followed:    (a) An annual/periodic inspection of the lockout/tagout program and procedures has not been conducted to ensure that procedures and requirements of the standard are being followed, and that employees who implement energy control procedures understand their application.