OSHA Inspection: MFG CHEMICAL INC.

Issued

Nov 19, 2012

Abate by

Nov 28, 2012

Penalty

Initial $3,500 · Current $2,625 Reduced

General-duty citation text

29 CFR 1910.37(a)(3): Exit route(s) were not kept free and unobstructed:    a) Warehouse and Maintenance Shop: The employer did not ensure that aisles and passageways were not obstructed by an excess amount of chemical storage. Employees were exposed to a fire/explosion hazard as a result of totes, drums and other storage obstructing the aisles.

Issued

Nov 19, 2012

Abate by

Nov 26, 2012

Penalty

Initial $3,500 · Current $2,625 Reduced

Hazardous substances 2150

General-duty citation text

29 CFR 1910.110(e)(4)(iii): Permanent and removable fuel containers were not securely mounted to prevent jarring loose, slipping, or rotating:    a) Process Area: The employer failed to ensure that a LP gas cylinder was secured on the Komatsu # 5 powered industrial truck. The latch designed to secure the cylinder was broken. Employees were exposed to a fire/explosion hazard while operating the industrial truck to move totes and drums containing chemicals in and around the process area.

Issued

Nov 19, 2012

Abate by

Mar 29, 2013

Penalty

Initial $4,900 · Current $3,675 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer did not develop piping and instrument diagrams for the equipment that was part of the process.    a) MFG Chemicals-Callahan: The employer did not develop P&ID (Piping and Instrumentation Diagram) that include all piping, equipment, valves and other components of the process equipment that existed within all major vessels exposing employees to a fire/explosion hazard. Employees were exposed to materials such as, but not limited to hydrogen peroxide, bromide, methanol, butanol and other highly hazardous materials.

Issued

Nov 19, 2012

Abate by

Jan 4, 2013

Penalty

Initial $4,900 · Current $3,675 Reduced

Hazardous substances 9730

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): Process Safety Information(PSI) pertaining to the equipment in the process did not include relief system design and design basis for all pressure vessels.    a) MFG Chemicals-Callahan: The employer did not maintain process safety information that contained calculations and design for relief devices that were utilized to protect pressure vessels D-5, D-6 and condensation receivers. Employees were exposed to the hazard of a run away reaction, fire/explosion hazard, toxic releases and other hazards while performing activities involving the manufacture of industrial materials. (Coagulate 129)

Issued

Nov 19, 2012

Abate by

Mar 29, 2013

Penalty

Initial $4,900 · Current $3,675 Reduced

Hazardous substances 9730

General-duty citation text

29 CFR 1910.119(e)(1): The employer did not perform an initial process hazard analysis (hazard evaluation) on processes covered by 29 CFR 1910.119:    a)  MFG Chemicals - Callahan Location: The employer did not conduct an initial Process Hazard Analysis (PHA) for all processes covered under process safety management. The employer did not establish a process evaluation to address industry recognized hazards, previous incidents, engineering and administrative controls, consequences for failure to documenting administrative controls and engineering controls, facility siting, human factors and evaluation of safety and health of the employees workplace.  Employees were exposed to fire/explosion hazards, chemical run away reactions, and other hazards while performing assigned duties for the manufacture of industrial chemicals. (Bromide CTC, AW-0075, and M-9867)

Issued

Nov 19, 2012

Abate by

Mar 29, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(iv): The employer initial process hazard analysis (hazard evaluation) on processes covered by 29 CFR 1910.119 did not consider the consequences of failure of engineering and adminstrative controls:    a)  MFG Chemicals - Callahan: The PHA for Coagulate 129 failed to address the consequences of failure in administrative controls and engineering controls. The employer utilized the City of Dalton as the main source of water. The employer made no provisions for a back-up source of water or other means to mitigate a run-away reaction. Employees were exposed to a fire/explosion hazard, chemical run-away reactions and other hazardous conditions while manufacturing industrial chemicals. (Coagulate 129).       1. The loss of water can occur when there is a main water break.    2. A low water table can occur during periods of drought.     3. During winter months, water freezes and pipes burst.    4. During summer months water temperature increases and compromise the effectiveness in cooling the water.    5. Low water pressure during periods of heavy usages by the surrounding carpet industry.     On May 21, 2012 a run-away reaction occurred in the D-6 reactor where Coagulate 129 was being batched. An increase in temperature of the product caused the reactor to overpressurize and resulted in an explosion. The explosion caused severe damage to the structure, equipment and an adjacent neighboring facility. Approximately 40 or more employees from neighboring companies were decontaminated and transported to local medical facilities for evaluation.

Issued

Nov 19, 2012

Abate by

Jan 4, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(v): The Process Hazard Analysis did not address facility siting.    a) MFG Chemicals, Callahan location: The Process Hazard Analysis for M-9863 and other covered processes did not address and consider facility siting of the operators control room that was located in the vicinity of six reactors. Employees were exposed to a fire/explosion hazard, a run-away reaction and other hazardous conditions while performing duties for the manufacture of industrial materials. i.e. methanol, butanol, bromide, hydrogen peroxide.

Issued

Nov 19, 2012

Abate by

Jan 31, 2013

Penalty

Initial $4,900 · Current $3,675 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 process safety information:    a)  MFG Chemicals-Callahan: The employer did not develop operating procedures for each covered process that addressed safe, accurate, concise instructions. Procedures did not include and reflect all current operating parameters to include, but not limited to, emergency shut down, personal protective equipment, consequences of deviation and temporary operations.  Employees were exposed to the hazard of a fire/explosion, run away reaction and other hazardous conditions while performing duties for the manufacture of industrial materials to include, but not limited to, (M-9866) and M-9867 (methanol), bromides (CTC_100, 300, 400) and other covered processes).

Issued

Nov 19, 2012

Abate by

Jan 31, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(g)(1):  The employer did not provide initial training on operating procedures for employees required to work on or near a covered process.    a) The employer did not provide initial training for all employees on standard operating procedures for covered processes. Employees were exposed to the hazard of fire/explosion, run away reaction and other hazardous conditions while performing duties for the manufacture of industrial materials to include, but not limited to, (M-9866 and M-9867 (methanol), bromides (CTC-100, 300, 400) and other processes.

Issued

Nov 19, 2012

Abate by

Mar 29, 2013

Penalty

Initial $4,900 · Current $3,675 Reduced

General-duty citation text

29 CFR 1910.119(f)(4): The employer did not develop or implement safe work practices for employees and contractors performing high risk maintenance activities on covered processes.    a) MFG Chemical-Callahan: The employer did not implement safe work practices for employees and contracted personnel engaged in performing the on-going mechanical integrity of process equipment. Contracted employees were exposed to materials such as, but not limited to, hydrogen peroxide, phenols, bromide and maleic acid while performing repairs and maintenance on reactors, condensers, piping and other equipment.

Issued

Nov 19, 2012

Abate by

Mar 29, 2013

Penalty

Initial $4,900 · Current $3,675 Reduced

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) MFG Chemicals-Callahan: The employer did not implement procedures for the on-going mechanical integrity of process equipment. Employees were exposed to materials such as, but not limited to, hydrogen peroxide, phenols, bromide and maleic acid while performing repairs and maintenance on reactors, condensers, piping and other equipment.

Issued

Nov 19, 2012

Abate by

Mar 29, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(3): The employer did not train employees, or contract employees, involved in maintaining the on-going integrity of process equipment in an overview of the inspection process and the procedures required to perform the employee's job tasks.    a) MFG Chemicals-Callahan: The employer did not provide training for the on-going mechanical integrity of process equipment. Employees were exposed to materials such as, but not limited to, hydrogen peroxide, phenols, bromide and maleic acid while performing repairs and maintenance on reactors, condensers, piping and other equipment.

Issued

Nov 19, 2012

Abate by

Dec 14, 2012

Penalty

Initial $4,900 · Current $3,675 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not implement procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process    a) MFG Chemicals-Callahan: The employer did not implement management of change procedures for each covered process which reflects deviation from normal operating procedures involving chemicals, equipment and other changes that may affect covered processes. Employees were exposed to the hazard of fire/explosion and other hazardous conditions while performing duties for the manufacture of industrial materials. (Coagulate 129).

Issued

Nov 19, 2012

Abate by

Dec 14, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(l)(3): The employer did not train employees in the changes to a covered process prior to start up.    a) MFG Chemicals-Callahan: The employer did not provide training on management of change for each covered process that reflect deviation from normal operating procedures involving chemicals, equipment and other changes which may affect covered procesess prior to start up of the process. Employees were exposed to the hazard of fire/explosion and other hazardous conditions while performing duties for the manufacture of industrial materials. (Coagulate 129).

Issued

Nov 19, 2012

Abate by

Jan 31, 2013

Penalty

Initial $4,900 · Current $3,675 Reduced

General-duty citation text

29 CFR 1910.119(n): The emergency action plan did not include procedures for handling small releases:    a) MFG Chemicals-Callahan: The employer did not provide training on management of change for each covered process that reflect deviation from normal operating procedures involving chemicals, equipment and other changes which may affect covered processes prior to start up of the process. Employees were exposed to the hazard of fire/explosion and other hazardous conditions while performing duties for the manufacture of industrial materials. (Coagulate 129).

Issued

Nov 19, 2012

Abate by

Jan 31, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.120(q)(6)(ii): First responders at the operational level did not receive at least eight hours of training or did not have sufficient experience to objectively demonstrate competency in the areas and/or the employer did not certify:    a) MFG Chemicals, Callahan Location: The employer did not ensure that employees participating in emergency response activities were provided training. Employees were exposed to the hazard of a fire/explosion, run away reaction and other hazardous conditions while performing duties involving repairing leaks ,line breaking, clean-up operations and other situation involving small emergency operations.

Issued

Nov 19, 2012

Abate by

Jan 31, 2013

Penalty

Initial $2,100 · Current $1,575 Reduced

General-duty citation text

29 CFR 1910.146(c)(2): The employer did not inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces:    a) Process Area: The employer did not post danger signs or other means to warn employees of permit required confined spaces on reactors, mixing tanks, receivers and other spaces. Employees were exposed to inhalation hazards, oxygen deficient atmospheres and other hazards while performing activities involving maintenance and repairs on process equipment.

Issued

Nov 19, 2012

Abate by

Dec 5, 2012

Penalty

Initial $3,500 · Current $2,625 Reduced

General-duty citation text

29 CFR 1910.146(e)(1): Before entry was authorized, the employer did not document the completion of measures required by 29 CFR 1910.146(d)(3) by preparing an entry permit:    a) Process Area: The employer did not ensure that confined space permits were issued and documented prior to employee's entry into reactors, tanks and other spaces. Employees were exposed to inhalation hazards, oxygen deficient atmospheres and other hazards while performing maintenance and other repairs on process equipment.

Issued

Nov 19, 2012

Abate by

Dec 5, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.146(g)(1): The employer did not provide training so that all employees whose work was regulated by 29 CFR 1910.146 (permit required confined spaces) acquired the understanding, knowledge, and skills necessary for the safe performance of the duties assigned under 29 CFR 1910.146:    a) Process Area: The employer did not ensure that training on confined space entry was provided to all employees participating in confined space entry activities. Employees were exposed to inhalation hazards, oxygen deficient atmospheres and other hazards while entering reactors, tanks and other spaces.

Issued

Nov 19, 2012

Abate by

Dec 5, 2012

Penalty

Initial $4,200 · Current $3,150 Reduced

Hazardous substances 2260

General-duty citation text

29 CFR 1910.151(c): Where employees were exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use:    The employer did not ensure that facilities for drenching and flushing the eyes and skin were available, maintained and/or accessible for employees exposed to caustic soda, maleic acid, SR-40L, SCP-250 and OS-31L while performing operator and maintenance duties.    a) Mezzanine Control Area: The eyewash/shower unit was blocked by a pallet containing chemicals.    b) Boiler Room: No eyewash/shower facility was maintained in the area.

Issued

Nov 19, 2012

Abate by

Nov 26, 2012

Penalty

Initial $3,500 · Current $2,675 Reduced

Hazardous substances T247

General-duty citation text

29 CFR 1910.157(c)(1): Portable fire extinguishers were not mounted, located and identified so that they were readily accessible without subjecting the employees to injuries:    Employees were exposed to a fire/explosion hazard while performing assigned activities involving the manufacture of industrial chemicals.      a) Lobby area:  A portable fire extinguishers was sitting on the floor by the door of the lobby entrance. (Badger NO) NIS 526970)    b) Operator control room: A portable fire extinguisher was sitting on the floor and utilized as a door stop. (Buckeye NO HISA 80 ABC)    c) W-2 tank mixing area-lower level: A portable fire extinguisher was located on the floor. (Badger NO XE 330685)

Issued

Nov 19, 2012

Abate by

Nov 28, 2012

Penalty

Initial $0 · Current $0

Hazardous substances T247

General-duty citation text

29 CFR 1910.157(e)(3): Portable fire extinguishers were not subjected to an annual maintenance check:    a) Control Room-Upper Mezzanine: A Badger NO XE 330685 fire control device did not receive an annual inspection. Employees were exposed to a fire/explosion hazard while performing assigned activities involving the manufacture of industrial chemicals.

Issued

Nov 19, 2012

Abate by

Dec 5, 2012

Penalty

Initial $0 · Current $0

Hazardous substances M317

General-duty citation text

29 CFR 1910.157(g)(3): Employees who have been designated to use fire fighting equipment as part of the emergency action plan were not provided training in the use of the appropriate equipment:    a) MFG Chemicals-Callahan: Employees were exposed to a fire/explosion hazard while performing assigned activities involving the manufacture of industrial chemicals.  Employees expected to utilized fire control devices were not provided appropriate hands on training on the use of the equipment.

Issued

Nov 19, 2012

Abate by

Nov 28, 2012

Penalty

Initial $3,500 · Current $2,625 Reduced

General-duty citation text

29 CFR 1910.165(b)(1): The employee alarm system did not provide warning for necessary emergency action as called for in the emergency action plan, or for reaction time for safe escape of employees from the workplace or the immediate work area, or both:    a) MFG Chemicals- Callahan: The employer did not ensure that a warning was sounded for employees, as called for in the employer's emergency action plan. On May 21, 2012, a run-away reaction occurred as a result of an increased temperature in the # D-6 reactor. The reaction resulted in over pressurization of the vessel, causing the rupture disc to blow. Employees were exposed to the hazards associated with hydroxgen peroxide, maleic acid and other materials. No warning sound was activated to notify employees to evacuate.

Issued

Nov 19, 2012

Abate by

Nov 28, 2012

Penalty

Initial $3,500 · Current $2,625 Reduced

General-duty citation text

29 CFR 1910.178(l)(1)(i): The employer did not ensure that each powered industrial truck operator was competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation specified in this paragraph (l)    a) MFG Chemicals-Callahan: The employer failed to ensure that employees operating an industrial forklift were provided training prior to operating the equipment. Employees were exposed to a struck by hazard, fire/explosion hazard and other hazards while operating the industrial truck to move totes and drums of chemicals in and around the facility.

Issued

Nov 19, 2012

Abate by

Nov 26, 2012

Penalty

Initial $3,500 · Current $2,625 Reduced

General-duty citation text

29 CFR 1910.253(b)(2)(iv):  Valve protection caps, where cylinders were designed to accept caps, were not always in place, hand-tight, except when cylinders were in use or connected for use:    a) Maintenance Shop:  Employees were exposed to struck by hazard and other hazards while performing maintenance and other activities. Two argon cylinders were in storage and missing their safety cap.

Issued

Nov 19, 2012

Abate by

Nov 28, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.253(b)(4)(iii): Oxygen cylinders were stored near acetylene or other fuel-gas cylinders:    a) Maintenance Shop:  Employees were exposed to a fire/explosion hazard while performing maintenance and other activities. Two acetylene and one oxygen cylinder were stored together outside the area.    b) Shipping and Receiving: Employees were exposed to a fire/explosion hazard while performing activities involving shipping and receiving. Two acetylene and three oxygen cylinders were stored together in the area.

Issued

Nov 19, 2012

Abate by

Nov 28, 2012

Penalty

Initial $2,800 · Current $1,880 Reduced

General-duty citation text

29 CFR 1910.305(b)(2): Pull boxes, junction boxes, and fittings were not provided with covers approved for the purpose:    a) Boiler Room: Employees were exposed to an electrical shock while performing maintenance, boiler treatment and other activities. The Square D panel box (120/240 volts) did not have a panel enclosure to protect the electrical circuits.

Issued

Nov 19, 2012

Abate by

Nov 26, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.303(f)(2): Each service, feeder, and branch circuit, at its disconnecting means or overcurrent device, was not legibly marked to indicate its purpose, nor located and arranged so the purpose was evident:    a) Boiler Room Area: Employees were exposed to an electrical shock while performing maintenance, boiler treatment and other activities. Electrical breakers in a Square D panel box were not identified to indicate their purpose.

Issued

Nov 19, 2012

Abate by

Nov 28, 2012

Penalty

Initial $3,500 · Current $2,625 Reduced

Hazardous substances 1470

General-duty citation text

29 CFR 1910.1200(f)(5)(i): The employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the identity of the hazardous chemical(s) contained therein:    a) Tank Farm: The employer did not ensure that two, approximately 10,000 gallon tanks of M-9840, were labeled to identify their content. Employees were exposed to the hazards of materials such as, but not limited to, hydrogen peroxide and maleic acid while performing activities for the manufacture of industrial materials.

Issued

Nov 19, 2012

Abate by

Dec 5, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 0842

General-duty citation text

29 CFR 1910.1200(g)(1): The employer did not have a material safety data sheet for each hazardous chemical in use:    a) Boiler room: The employer did not maintain a material safety data sheet for materials such as, but not limited to, SR-40L, SCP-250 and OS-31L. Employees were exposed to chemical burns while performing boiler treatment utilizing corrosive materials.

Issued

Nov 19, 2012

Abate by

Dec 5, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 1470

General-duty citation text

29 CFR 1910.1200(h)(1): Employees were not provided effective information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard that the employees had not been previously trained about was introduced into their work area:    a) MFG Chemicals-Callahan: The employer did not provide training on hazard communication for all employees exposed to materials such as, but not limited to, hydrogen peroxide, phenols, bromide and maleic acid while performing activities for the manufacture of industrial materials.