OSHA Inspection: FONTAROME CHEMICAL, INC.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $2100.00 · Current $1050.00 Reduced

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.    (a) No written program outlining how the company involves employees in the development, management, implementation and review of the process safety managment program was developed.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $3500.00 · Current $1750.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i):     The employer did not compile information pertaining to the equipment in the process.    (a) P&ID's:     1. P&ID's were not developed for, but not limited to, the scrubber, chilled cooling water system, steam system, and nitrogen gas supply system.    2. P&ID's for reactors PC-52, PC-201 and PC-501 were not complete in-that the P&ID's did not have a legend, and did not identify pressure relief valves.    3. P&ID's were not updated to reflect changes in the process equipment. The glycol cooling system was removed from the process and is reflected on the P&ID's for reactors PC-52, PC-201 and PC-501.     (b) Information outlining electrical classification of process equipment was not compiled.    (c) Information outling pressure relief devices and systems associated with covered process equipment was not compiled.    (d) Information outlining ventilation system design was not compiled.    (e) Information outlining the design codes and standards used for construction of equipment and processes was not compiled.    (f) Information outling the safety systems employed for use with process equipment and associated process equipment and utilities was not compiled.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(d)(3)(ii):     The employer did not document that equipment complies with recognized and generally accepted good engineering practices.    (a) Pfaudler Reactor PC-52: The U-1 Form, Manufacturer's Certificate of Compliance Covering Pressure Vessels was not maintained to document that the reactor complied with recognized and generally accepted good engineering practices (RAGAGEP).    (b) Pfaudler Reactor PC-201: The U-1 Form, Manufacturer's Certificate of Compliance Covering Pressure Vessels was not maintained to document that the reactor complied with recognized and generally accepted good engineering practices (RAGAGEP).    (c) Pfaudler Reactor PC-501: The U-1 Form, Manufacturer's Certificate of Compliance Covering Pressure Vessels was not maintained to document that the reactor complied with recognized and generally accepted good engineering practices (RAGAGEP).    (d) The covered process uses glass piping to process, transfer and separate out liquid materials created during the reaction process. The company did not document that the glass piping for reactors PC-52, PC 201, and PC 501 complied with recognized and generally accepted good engineering practices (RAGAGEP).    (e) The covered process uses clamps to connect glass piping and other reactor process components. The company did not document that the clamps complied with recognized and generally accepted good engineering practices (RAGAGEP).    (f) The covered process uses an Emissions Scrubber that was not documented as complying with Recognized and generally Accepted Good Engineering Practices(RAGAGEP).    (g) The covered process uses a steam system for heating the reactor vessels. The steam generation system was not documented as complying with Recognized and Generally Accepted Good Engineering Practices (RAGAGEP).    (h) The covered process uses Local Exhaust to remove vapor and gas byproducts from the process. The local exhaust system was no documented as complying with Recognized and Generally Accepted Good Engineering Practices (RAGAGEP).

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $3500.00 · Current $1750.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(2):  The employer did not conduct a process hazard analysis (PHA) using one of the established methodologies identified in 29 CFR 1910.119(e)(2)(i) through (vii).    (a) A Process Hazard Analysis was conducted using a Stepwise methodology that did not meet requirements of (e)(2)(i) through (viii).

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(e)(3)(i):     The process hazard analysis did not address the hazards of the process.    (a) The process hazard analysis did not address hazards of the process such as loss of cooling for the reactors, electrical power outages, failure of the scrubber, occurrence of leaks, failure of safety/alarm devices, failure of steam system and piping, generation of Sulfur Dioxide and Hydrochloric Acid, and outside environmental impacts.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(e)(5):     The employer did not assure that PHA recommendations were resolved in a timely manner.    (a) A system was not established to document PHA recommendations, and to track recommendations through a review and resolution process.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $2100.00 · Current $1050.00 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.    (a) A five (5) year revalidation of the 2004 PHA has not been completed to reflect changes to the process.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $3500.00 · Current $1750.00 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:    Operating procedures were not developed for processes associated with the use of Thionyl Chloride.    (a) Procedures were not developed for draining aqueous solutions from reactors, bell and water traps, and other auxiliary equipment associated with the process.    (b) An operating procedure was not developed for placing the reactor(s) under vacuum.    (c) Grounding and Bonding Methods: An operating procedure was not developed for when product materials are drained from reactors, charging bells or other process devices into drums or other containers.     (d) Cooling Systems: A procedure for charging cooling glycol and cooling water and discharging cooling glycol and cooling water from the cooling jacket on the reactors was not developed.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(f)(1)(i)(D):     The employer did not develop and implement written operating procedures that provide clear instructions for 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.    (a) Written procedures that cover emergency operation and/or shut down of reactors, scrubber, steam system, chilled water system, and other auxiliary equipment associated with the covered process, were not developed to ensure safe operation or shut down when processes deviate from safe operating parameters.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(f)(1)(i)(E):     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 and did not address at least emergency operations.       (a) Written procedures that cover emergency operations for processes that use Thionyl Chloride were not developed.  Specific process functions that were not addressed are, but not limited to:    1. Loss of Nitrogen flow to reactor.  2. Loss of cooling to the reactor.  3. Excessive off-gassing leading to oversaturation of scrubber.  4. Development of leak from glass piping or other auxiliary component.  5. Loss of vacuum from the process.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $2100.00 · Current $1050.00 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 associated with the use of Thionyl Chloride were not certified as current and accurate on an annual basis.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $3500.00 · Current $1750.00 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 a covered process or have work duties associated with the covered process were not trained in an overview of processes that involve Thionyl Chloride. Employees were not familiar with the following aspects of process safety management (PSM), but not limited to:    1. What process safety management is.  2. Processes covered under process safety management.  3. Employee responsibilities and involvement regarding process safety management.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(g)(2):     Refresher Training: Refresher training was not provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process. The employer, in consultation with the employees involved in operating the process, shall determine the appropriate frequency of refresher training.    (a)  Employees who operate covered process or have work duties associated with the covered process have not had refresher training on the process every three years. Training for employees was last conducted in 2007 and 2008.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $4900.00 · Current $2450.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i):     The employer did not perform inspection and tests on process equipment:    Inspection and testing of Process Safety Management (PSM) covered process equipment has not been accomplished for, but is not limited to the following equipment:    (a) Inspection of Pfaudler reactor vessels PC-52 , PC-201 and PC-501 were not periodically inspected as required by Pfaudler preventive maintenance requirements. The reactors were last inspected beyond a visual inspection in February of 2010.    1. Reactor agitating nozzles and impingement plates in jacket connections were not inspected every 6 months as required by Pfaudler preventive maintenance requirements.    2. Reactor steam heating and water cooling jacket on the reactor vessels were not inspected periodically as required by Pfaudler preventive maintenance requirements. .    (b) Steam System: Piping and process valves through which steam is transported to reactors has not been inspected for fitness-for-service and remaining life of the steam lines.     (c) Chilled water system had not been inspected since 2010.    (d) Glass Process Piping: Process piping has not been inspected to determine fitness-for-service and remaining life beyond a visual inspection.    (e) Scrubber System: The scrubber system has not been inspected beyond a visual inspection since 2010.    (f) Nitrogen Distribution System: The system has not been inspected to ensure piping, valves and all other associated equipment is functioning as designed.    (g) Local Exhaust System: The local exhaust system has not been inspected to ensure that equipment is functioning as designed and that air flow capture velocity is within design specifications.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(j)(4)(ii):     Inspection and testing procedures did not follow recognized and generally accepted good engineering practices:    (a) Inspection of Pfaudler reactor vessels PC-52 , PC-201 and PC-501 did not follow recognized and generally accepted good engineering practices (RGAGEP).     1. Reactors were not inspected periodically as required by Pfaudler preventive maintenance requirements. The reactors were last inspected beyond a visual inspection in February of 2010.    2.The glasteel lining of the reactors have not been spark tested.    3. Glasteel lining of the reactors have not had thickness testing done.    4. Reactor agitating nozzles and impingement plates in jacket connections are not inspected every 6 months.    5. Reactor steam heating and water cooling jacket on the reactor vessels was not inspected periodically.    (b) Steam System: Piping and process valves through which steam is transported to reactors has not been evaluated for fitness-for-service and remaining life of the steam lines. Such evaluation is but not limited to thickness testing to determine rate of erosion and corrosion.    (c) Chilled water system had not been inspected since 2010.    (d) Glass Process Piping: Process piping has not been inspected to determine fitness-for-service and remaining life. Such evaluation is but not limited to thickness testing to determine rate of erosion.    (e) Scrubber System: The scrubber system has not been inspected beyond a visual inspection since 2010.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $3500.00 · Current $1750.00 Reduced

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) before use.    (a) Reactor PC-52:    1. Yellow painted pipe located above glycol return pipe was free hanging and not supported. No pipe end plug was in place at end of pipe valve or valve handle was not locked out to prevent inadvertent opening and release of material from the pipe.    2. End pipe cover was held in place with duct tape.    3. Local exhaust flexible duct work was held in place on process equipment using duct tape.    4. Local exhaust duct connection point to the exhaust header duct was broken away from header duct.    (b) Reactor PC-501: Pressure gauge on the steam line entering into the reactor heating jacket was damaged, in-that the glass covering was broken away.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $2100.00 · Current $1050.00 Reduced

General-duty citation text

29 CFR 1910.119(l)(2):     The procedures did not assure that the following considerations are addressed prior to any change:    (a) The Change Control Procedure (SOP QA-015-012) did not specifically address the process safety management  performance requirements of management of change, in-that the procedure did not address the technical basis for proposed change(s),  impact of change on safety and health, modifications to operating changes, necessary time period for the change, and authorization requirements for the proposed change to the process.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $2100.00 · Current $1050.00 Reduced

General-duty citation text

29 CFR 1910.119(o)(1):     The employer did not verify that the procedures and practices developed under the standard were being followed:    (a)  A compliance audit of the process safety management program has not been accomplished to ensure procedures and practices developed are current, adequate and are being followed.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $3500.00 · Current $1750.00 Reduced

General-duty citation text

29 CFR 1910.147(c)(4)(i):     Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:    (a) Written step by step procedures were not developed for authorized personnel to follow when accomplishing maintenance or servicing work on but not limited to reactors, scrubber system, steam system, local exhaust system, hot oil system,  chilled cooling water system and equipment and processes that have more than 1 energy source. This exposed personnel to caught-in, crushing, amputation, struck by, and burn hazards.

Issued

2012-09-28 00:00:00

Abate by

2013-09-13 00:00:00

Penalty

Initial $2100.00 · Current $1050.00 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 energy control 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.

Issued

2012-09-28 00:00:00

Abate by

2012-10-05 00:00:00

Penalty

Initial $2800.00 · Current $1400.00 Reduced

General-duty citation text

29 CFR 1910.212(a)(1):     Machine guarding was not provided to protect operator(s) and other employees from hazard(s) created by rotating parts:    (a) Vertical rotating shaft located on top of reactor PC-501 was not guarded, exposing employees to a caught-on and/or snagging hazard.

Issued

2012-09-28 00:00:00

Abate by

2012-10-01 00:00:00

Penalty

Initial $3500.00 · Current $1750.00 Reduced

General-duty citation text

29 CFR 1910.305(b)(2)(i):     Each outlet box in completed installations did not have a cover, faceplate, or fixture canopy:    (a) Utility/Pump Room: Numerous electrical pull boxes and junction boxes located on the east wall and north wall did not have covers in place, exposing the energized electrical componets to inadvertent contact by maintenance and operations personnel. This exposed employees to electrical shock and arc flash hazards.

Issued

2012-09-28 00:00:00

Abate by

2012-11-13 00:00:00

Penalty

Initial $3500.00 · Current $1750.00 Reduced

General-duty citation text

29 CFR 1910.333(a):     Safety-related work practices were not employed to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts, when work was performed near or on equipment or circuits which were or could be energized:    (a) Maintenance employees did not implement electrical safety-related work practices when performing work on a 120 Volt AC Thermocoupler for the hot oil system, exposing them to electrical shock and burn hazards from direct and indirect electrical contacts. Electrical safety related work practices (ESRWP) to be employed, but is not limited to electrical hazard evaluation, testing and verification procedures, lockout of electrical cicuits and traning of employees on electrical safety-related work practices (ESRWP).

Issued

2012-09-28 00:00:00

Abate by

2012-11-13 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.335(a)(1)(i):     Employees working in areas where there were potential electrical hazards were not using electrical protective equipment that was appropriate for the specific parts of the body to be protected and for the work to be performed:    (a) Employee(s) worked on or around energized 120 Volt AC electrical thermocouple and associated equipment on the hot oil system. Employees did not use personal protective equipment such as calorie-rated face shield, flash hood and/or suit, gloves, non-conductive hard hat, insulating gloves and flame-resistant/calorie rated clothing to protect against arc flash and shock hazards.