OSHA Inspection: ONLINE PACKAGING INCORPORATED

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $2800.00 · Current $1700.00 Reduced

General-duty citation text

29 CFR 1910.119(c)(3): The employer did not provide to employees and their representatives access to process hazard analyses and to all other information required to be developed under 29 CFR 1910.119.    The employer does not ensure that the employees have access to the process hazard analysis and other process safety information required by the standard to be developed and maintained at the facility for the bleach production process. This condition exposed employees to the hazards associated with the release of chlorine liquid and/or vapor into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $4900.00 · Current $3300.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i)(D): Process safety information pertaining to the technology of the process did not include the safe upper and lower limits for such items as temperatures, pressures, flows or compositions:    The employer does not ensure that safe upper and lower operating limits (temperature, pressure, flow, and composition) are developed and maintained and are included in the process safety information for the bleach production unit exposing employees to the hazards associated with the release of chlorine liquid and/or vapor into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(d)(2)(i)(E):  Process safety information pertaining to the technology of the process did not include an evaluation of the consequence of deviations, including those affecting the safety and health of employees.    The employer does not ensure that an evaluation of the consequences of deviation from the high and lower safe operating limits is completed, maintained, and included the process safety information for the bleach production unit thereby exposing employees to the hazards associated with the release of chlorine liquid and/or vapor into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B):  Process safety information pertaining to the equipment in the process did not include the piping and instrument diagrams (P&ID'S).    The employer does not ensure that piping and instrument diagrams (P&IDs) are developed and maintained in the process safety information for the bleach production unit. This condition exposed employees to the hazards associated with the release of chlorine liquid and/or vapor into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(d)(3)(i)(G): Process safety information pertaining to the equipment did not include the material and energy balances for processes built after May 26, 1992:    The employer does not ensure that a material and energy balance(s) is developed and maintained and included in the process safety information for the bleach production unit exposing employees to the hazards associated with the release of chlorine liquid and/or vapor into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $4900.00 · Current $3300.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process:    The employer does not ensure that hazards of the process are addressed in the bleach production unit such as but not limited to:   a.	Loss of utilities such as power, cooling water, and compressed air  b.	Chlorine release due to over-chlorination.   These violation instances exposed employees to the hazards associated with uncontrolled releases of chlorine liquid and/or vapor into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(e)(4): The team performing the process hazard analyses did not include at least one employee who had experience and knowledge specific to the process being evaluated:    The employer does not ensure that the team performing the process hazards analysis of the bleach production process has at least one employee with experience and knowledge specific to the process thereby exposing employees to the hazards associated with the release of chlorine liquid and/or vapor into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(e)(5):  The employer did not establish a system to promptly address the process hazard analysis team's findings and recommendations:    The employer does not ensure that a system is established to promptly address the process hazard analysis teams findings and recommendations and that the recommendations are addressed in a timely manner for the bleach production process thereby exposing employees to the hazards associated with the release of chlorine liquid and/or vapor into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $4900.00 · Current $3300.00 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(A): The employers written operating procedures covering the operating limits did not address consequences of deviation beyond such operating limits.     The employer does not ensure that the operating procedures address the consequences of deviation from the established operating limits such as but not limited to:  a.	Temperature on the outlet of the bleach and the caustic heat exchanger(s)  b.	Pressure on the rail car/feed line to the bleach production skid  c.	Flow of caustic and liquid chlorine to the bleach production skid.  These violation instances occurred in the bleach production unit and exposed employees to the hazards associated with the release of chorine liquid and/or vapor into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(B): The employer written operating procedures covering the operating limits did not address the steps required to correct or avoid deviation beyond such operating limits.     The employer does not ensure that the operating procedures address the steps required to avoid deviation from the established operating limits such as but not limited to:   a.	Temperature on the outlet of the bleach and the caustic heat exchanger(s)  b.	Pressure on the rail car/feed line to the bleach production skid  c.	Flow of caustic and liquid chlorine to the bleach production skid.  These violation instances occurred in the bleach production unit and exposed employees to the hazards associated with the release of chorine liquid and/or vapor into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(f)(1)(iv):  The employer's written operating procedures did not address requirements for the safety systems and their functions:    The employer does not ensure that the written operating procedures for the bleach production unit addressed safety systems and their functions such as but not limited to:   a.	Rail Car Emergency Shut-off System  b.	Chlorine Atmospheric Sensors  c.	Circulation Pump Interlock  d.	High Bleach Temperature Interlock.   These violation instances occurred in the bleach production unit and exposed employees to the hazards associated with the release of chorine liquid and/or vapor into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $4900.00 · Current $1900.00 Reduced

General-duty citation text

29 CFR 1910.119(g)(2): The employer did not provide refresher training 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 does not ensure that employees involved in the operation of the bleach production unit are provided refresher training every three years, and more often if necessary, and that employees understand and adhere to the current operating procedures thereby exposing employees to the hazards associated with the release of chlorine liquid and/or vapor or sodium hypochlorite into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $0.00 · Current $0.00

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.    The employer does not ascertain and document that each employee involved in operating a process have received and understood the training thereby exposing employees to the hazards associated with the uncontrolled release of chlorine liquid and/or vapor into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $4900.00 · Current $3300.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going mechanical integrity of process equipment.    The employer does not ensure that written procedures are established and implemented in the bleach production unit to maintain the on-going mechanical integrity of process equipment such as but not limited to:   a.	Rail Car Emergency Shut-off System  b.	Chlorine Atmospheric Sensors and Alarms listed as a safeguard in the 2007 Bleach                   Unit PHA  c.	Flow Sensor that stops chorine flow in the event of no flow through the recirculation                   pump listed as a safeguard in the 2007 Bleach Unit PHA  d.	High Bleach Temperature Interlock  e.	Liquid Chlorine Piping from the rail car to the bleach production unit.   These violation instances exposed employees to the hazards associated with the release of chorine liquid and/or vapor into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(j)(4)(i):  Inspections and tests were not performed on process equipment to maintain its mechanical integrity:    The employer does not ensure that inspection and tests are performed on process equipment in the bleach production unit to maintain its mechanical integrity for such equipment as but not limited to:  a.	Chlorine Atmospheric Sensors  b.	High Bleach Temperature Interlock  c.	Bleach Production Unit Heat Exchanger(s)  d.	ORP (Oxidation Reduction Potential) Controls.   These violation instances exposed employees to the hazards associated with the release of chorine liquid and/or vapor into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(j)(4)(iv):  The documentation of the inspection or test that been performed on process equipment to maintain its mechanical integrity did not include a description of the inspection or test:    The employer does not ensure that the inspection or tests that had been performed on process equipment to maintain its mechanical integrity included a description of the inspection or test for process equipment such as but not limited to:  a.	Rail Car Emergency Shut-off System  b.	Chlorine Atmospheric Sensor Alarms  c.	Flow Sensor (Tank Circulating Alarm)  These violation instances occurred in the bleach production unit and exposed employees to the hazards associated with the release of chorine liquid and/or vapor into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $4900.00 · Current $3300.00 Reduced

General-duty citation text

29 CFR 1910.119(o)(1):  The employer did not certify that they had evaluated compliance with the provisions of 29 CFR 1910.119 at least every three years to verify that the procedures and practices developed under this standard were adequate and are being followed.    The employer does not ensure that process safety management compliance audits are conducted for the bleach production process every three years as required by the standard thereby exposing employees to the hazards associated with uncontrolled releases of chlorine liquid and/or vapors into the atmosphere.

Issued

2012-10-02 00:00:00

Abate by

2012-10-12 00:00:00

Penalty

Initial $4900.00 · Current $1900.00 Reduced

General-duty citation text

29 CFR 1910.132(d)(1):  The employer did not assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE):    The employer does not ensure that an assessment of the workplace was completed to determine if hazards are present or likely to be present which necessitate the use of personal protective equipment thereby exposing employees to dermal hazards associated with packaging sodium hypochlorite and the hazards associated with uncontrolled releases of chlorine liquid and/or vapors into the atmosphere.