OSHA Inspection: 5N PLUS INC.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

General-duty citation text

29 CFR 1910.119(c)(1): The employer did not develop a written plan of action regarding the implementation of employee participation.    Location: 515 Commerce Drive, Fairfield, CT    A written plan of action for employee participation for the gallium trichloride process safety management plan was not developed and implemented.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(c)(2): Employers did not consult with employees and their representatives on the conduct and development of process hazard analyses and on the development of the elements of process safety management in this standard.    Location: 515 Commerce Drive, Fairfield, CT    Employees were not consulted on the conduct and development of process hazard analyses and on the development of the elements of process safety management in this standard concerning the gallium trichloride process.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(c)(3): The employer did not provide employees and their representatives access to process hazard analyses and to all other information required to be developed under this standard.    Location: 515 Commerce Drive, Fairfield, CT    Employees were not provided with access to the HAZOP study and the What-If process hazard analyses and all other information contained in the company's PSM plan for the gallium trichloride process.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

General-duty citation text

29 CFR 1910.119(d)(2)(i)(D): Safe upper and lower limits for such items as temperature, pressures, flows or compositions pertaining to the technology of the process were not compiled before conducting any process safety analysis required by this standard.    Location: 515 Commerce Drive, Fairfield, CT    The upper and lower temperature and pressure limits, flows and compositions were not complied for the small 35 Kg #7-#11 reactors and the 180 Kg GLR1 reactor prior to the process safety analyses being completed.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): Relief system design(s) and design basis' pertaining to the equipment in the process were not compiled before conducting any process safety analysis required by this standard.    Location: 515 Commerce Drive, Fairfield, CT    Relief system designs and design basis' pertaining to reactor #1 through #11 and the GLR1 reactor were not compiled before conducting the process hazard analyses.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F): Design codes and standards pertaining to the equipment in the process were not compiled before conducting any process safety analysis required by this standard.    Location: 515 Commerce Drive, Fairfield, CT    Design codes and standards were not compiled prior to the process hazard analyses being conducted for the gallium trichloride progress.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

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.    Location: 515 Commerce Drive, Fairfield, CT    The employer did not documented that reactors #1 through #11, the GLR1 reactor, the chlorine storage and distribution system and the chlorine alarm system complied with recognized and generally accepted good engineering practices.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the team's findings and recommendations; did not assure that the recommendations were resolved in a timely manner and that the resolution was documented; did not document what actions were to be taken; did not complete actions as soon as possible; did not develop a written schedule of when these actions were to be completed; did not communicate the actions to operating, maintenance and other employees whose work assignments were in the process and who may have been affected by the recommendations or actions:    Location: 515 Commerce Drive, Fairfield, CT    1. A system to promptly address the findings and recommendations following the Process Hazard Analysis (PHA) using the HAZOP study in July 2011 was not developed, implemented and completed.    2. A system to promptly address the findings and recommendations following the Process Hazard Analysis (PHA) using the What-If study in September 2011 following the August 2011 incident with the gallium trichloride process was not developed, implemented and completed.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

General-duty citation text

29 CFR 1910.119(f)(2): Operating procedures were not readily accessible to employees who work in or maintain a process area.    Location: 515 Commerce Drive, Fairfield, CT    The operating procedures for the gallium trichloride process contained in the Process Safety Management (PSM) plan were not readily available to employees working in the galium trichloride process.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(f)(3): The operating procedures were not reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities.    Location: 515 Commerce Drive, Fairfield, CT    The standard operating procedures were not reviewed and updated to reflect changes made when the GLR1 reactor was received, installed and placed into operation.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

General-duty citation text

29 CFR 1910.119(g)(1)(i): The employer did not train each employee in an overview of the process and in the operating procedures as specified in paragraph (f) of 29 CFR 1910.119 .    Location: 515 Commerce Drive, Fairfield, CT    Each employee involved in the gallium trichloride process was not provided with training that included an overview of the process and in the operating procedures contained in the company's Process Safety management (PSM) plan for the gallium trichloride process.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(g)(3): The employer did not ascertain that each employee involved in operating a process has received and understood the training required by this paragraph and did not 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.    Location: 515 Commerce Drive, Fairfield, CT    The employer did not ascertain that each employee involved with the gallium trichloride process had received and understood the Process Safety Management (PSM) training required by this paragraph and did not prepare a record that contains the identity of the employee, the date of the training and the means used to verify the training was understood.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

General-duty citation text

29 CFR 1910.119(h)(2)(i): The employer, when selecting a contractor, did not obtain and evaluate information regarding the contract employer's safety performance and programs.    Location: 515 Commerce Drive, Fairfield, CT    The employer, when selecting contactors to work in the gallium trichloride process area, did not evaluate each contractor's safety performance and safety programs.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(h)(2)(ii): The employer did not inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process.    Location: 515 Commerce Drive, Fairfield, CT    The employer did not inform contract employers working in the gallium trichloride process area of the fire, explosion, health and toxic hazards associated with the gallium trichloride process.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(h)(2)(iii): The employer did not explain to contract employers the applicable provisions of the emergency action plan required by paragraph (n) of this section.    Location: 515 Commerce Drive, Fairfield, CT    Contract employees including electrical and plumbing contractor employees were not informed of and explained the provisions of the company's emergency action plan.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(h)(2)(vi): The employer did not maintain a contract employee injury and illness log related to the contractor's work in process areas.    Location: 515 Commerce Drive, Fairfield, CT    A contractor employee injury and illness log related to the contractor's work in the gallium trichloride process area was not maintained.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $3,500 · Current $3,500

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.    Location: 515 Commerce Drive, Fairfield, CT    A pre-startup safety review(PSSR) was not completed when reactors #7-#11 and the GLR1 reactor was started in the gallium trichloride processing area.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

General-duty citation text

29 CFR 1910.119(i)(2)(iv): Each employee involved in operating a process that has been changed was not trained.    Location: 515 Commerce Drive, Fairfield, CT    Employee involved in the gallium trichloride when the GLR1 reactor was introduced to the process was not provided with training.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(3): The employer did not 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.    Location: 515 Commerce Drive, Fairfield, CT    Employees working in the gallium trichloride process area were not provided with training in the on-going integrity of the process equipment, an overview of the process, the hazards associated with the process and in the procedures to assure the employees performed their job tasks safely.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

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.    Location: 515 Commerce Drive, Fairfield, CT    Inspection and testing procedures for the small #1-#11 reactors, the GLR1 reactor and the chlorine supply and distribution system did not follow recognized and generally accepted good engineering practices.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(iv): The documentation of each inspection and test that was performed on the process did not identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test:    Location: 515 Commerce Drive, Fairfield, CT    Inspection documentation for the chlorine systems, chlorine piping, small reactors and the GLR1 reactor did not identify the date of the inspection, name of the person performing the inspection, a description of the inspection or test and the results of the inspection or test.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

General-duty citation text

29 CFR 1910.119(j)(6)(i): In the construction of new plants and equipment, the employer did not assure that equipment as it is fabricated is suitable for the process application for which they will be used.    Location: 515 Commerce Drive, Fairfield, CT    The employer did not assure the GLR1 reactor was designed, fabricated and modified for the gallium trichloride process.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(6)(ii): Appropriate checks and inspections were not performed to assure that equipment was installed properly and consistent with design specifications and the manufacturer's instructions.    Location: 515 Commerce Drive, Fairfield, CT    Checks and inspections were not performed on the GLR1 reactor to assure the reactor was installed properly and consistent with the design specifications and manufacturer's inspections.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not establish written procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process.    Location: 515 Commerce Drive, Fairfield, CT    Written procedures to manage changes when the GLR1 reactor was added to the gallium trichloride process were not established and implemented.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

General-duty citation text

29 CFR 1910.119(l)(3): The employer did not provide training to employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process in the changes to a covered process prior to start up.    Location: 515 Commerce Drive, Fairfield, CT    Employees involved in the gallium trichoride process were not provided with training in the changes to the gallium trichoride process when reactor #7 through #11 and the GLR1 reactor were installed and prior to their start up.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

General-duty citation text

29 CFR 1910.119(l)(4): Process safety information required by paragraph (d) of this section was not updated when a change covered by this paragraph resulted in a change in the process safety information.    Location: 515 Commerce Drive, Fairfield, CT    Process safety information required by paragraph (d) of the this section was not updated when the GLR1 reactor was installed and placed into operation.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

General-duty citation text

29 CFR 1910.119(l)(5): When a change covered by this paragraph resulted in a change in the operating procedures or practices required by paragraph (f) of this section, such procedures or practices were not updated accordingly.    Location: 515 Commerce Drive, Fairfield, CT    Changes to the operating procedures or practices required by paragraph (f) of this section were not conducted when the GLR1 reactor was install and used.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

29 CFR 1910.119(m)(5): The employer did not establish a system to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions shall be documented.    Location: 515 Commerce Drive, Fairfield, CT    A system to promptly address and resolve the August 2011 incident report's findings and recommendations was not established with the resolutions and corrective actions being documented.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

General-duty citation text

29 CFR 1910.119(m)(6): Incident investigation reports were not reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable.    Location: 515 Commerce Drive, Fairfield, CT    The August 9, 2011 incident report involving the gallium trichloride process was not reviewed with all affected employees working in the gallium process area.

Issued

Oct 11, 2012

Abate by

Oct 21, 2012

Penalty

Initial $2,800 · Current $2,800

General-duty citation text

29 CFR 1910.119(n): The employer did not establish an emergency action plan to include procedures for handling small releases for the entire plant:    Location: 515 Commerce Drive, Fairfield, CT    The company did not establish an emergency action plan to include procedures for handling small releases of chlorine and gallium trichoride.