OSHA Inspection: FELDA IFFCO, LLC.

Issued

Apr 16, 2013

Abate by

May 31, 2013

Penalty

Initial $3,570 · Current $0 Reduced

Hazardous substances 22609135

General-duty citation text

29 CFR 1910.22(b)(1):  Aisles and passageways were not kept clear and in good repair, with no obstruction across or in aisles that could create a hazard.    a)  The material used to cover the concrete on the ground floor of the unit where the sodium methylate powder was stored and transported had worn away and broken so that it presented a trip hazard to employees who carried 25 pound bags of this corrosive and combustible chemical up to the reaction hopper.      In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

May 10, 2013

Penalty

Initial $2,975 · Current $1,500 Reduced

General-duty citation text

29 CFR 1910.28(a)(12):  An access ladder or equivalent safe access was not provided.    a)  The access to the scaffold at the methylate reactor that was used to enable employees to pour 25 pound bags of sodium methylate powder into the reaction hopper was greater than 24 inches tall and did not have a ladder or stairs for safe access.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

May 10, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.28(c)(6):  All tube and coupler scaffolds was not erected by competent and experienced personnel.    a)  The employer had no record of when the scaffold at the methylate reactor was installed or who had installed it approximately four years ago.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

May 10, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.28(c)(7):  Posts were not accurately spaced, erected on suitable bases, and maintained plumb.    a)  The scaffold at the methylate reactor was not erected on suitable bases and the employer had no records to indicate it was maintained plumb, even though it appeared to be plumb at the time of the inspection.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

May 10, 2013

Penalty

Initial $1,785 · Current $900 Reduced

Hazardous substances 1660

General-duty citation text

29 CFR 1910.38(c)(6):  The emergency action plan did not include the name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan.    (a)  The employer did not update the SOP for emergency response to include an alternate or new contact for the emergency response coordinator, who had been the Safety, Health and Environmental manager (SHE), when that SHE manager was laid off on November 1, 2012.      (b)  The former SHE manager was listed on all Rip-Run Forms in the emergency response plan as the emergency response coordinator, who was to be contacted in case an emergency occurred.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

May 10, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1660

General-duty citation text

29 CFR 1910.119(n):  The employer did not implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38:    (a)  The employer did not update the SOP for emergency response to include an alternate or new contact for the emergency response coordinator, who was the Safety, Health and Environmental manager, when the SHE manager was laid off on November 1, 2012.      (b)  The former SHE manager was listed on all Rip-Run Forms in the emergency response plan as the emergency response coordinator, who was to be contacted in case an emergency occurred.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

Jun 28, 2013

Penalty

Initial $4,900 · Current $4,000 Reduced

Hazardous substances 1660

General-duty citation text

29 CFR 1910.119(e)(6):  At least every five (5) years after the completion of the initial process hazard analysis, the process hazard analysis was not updated and revalidated by a team meeting the requirements in paragraph (e)(4) of this section, to assure that the process hazard analysis was consistent with the current process.    (a)  The employer had not conducted a PHA re-validation since 2007, the year that the current owner purchased the company.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

Jun 3, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1660

General-duty citation text

29 CFR 1910.119(e)(7):  The employer did not retain process hazards analyses and updates or revalidations for each process covered by this section, as well as the documented resolution of recommendations described in paragraph (e)(5) of this section for the life of the process.    (a)  The employer did not have a copy of the 2007 PHA re-validation for the methanol system.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

Jun 3, 2013

Penalty

Initial $4,900 · Current $4,000 Reduced

Hazardous substances 1660

General-duty citation text

29 CFR 1910.119(g)(2):  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 understood and adhered to the current operating procedures of the process.     (a)  Employees had not been given refresher training on methanol process safety management since 2009.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

Jun 3, 2013

Penalty

Initial $4,900 · Current $2,500 Reduced

Hazardous substances 1660

General-duty citation text

29 CFR 1910.119(o)(1):  The employer did not certify that they had evaluated compliance with the provisions of this section at least every three years:    (a)  The employer had not conducted a PHA compliance audit at the facility since 2007, the year that Felda purchased the company.  The audit was conducted by the previous owner, Twin Rivers.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

Jun 28, 2013

Penalty

Initial $4,900 · Current $2,500 Reduced

Hazardous substances 22609135

General-duty citation text

29 CFR 1910.132(a):  Protective equipment was not used when necessary whenever hazards capable of causing injury and impairment were encountered:    a)  Employees were not required to wear appropriate personal protective equipment when they carried 25 pound bags of sodium methylate powder, a highly corrosive chemical and a combustible dust that was shipped in closed drums, up six flights of stairs in the open air to the methylate reactor on the third floor of the structure.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

Jun 28, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 166022609135

General-duty citation text

29 CFR 1910.132(d)(1):  The employer did not assess the workplace to determine if hazards were present, or were likely to be present, which necessitated the use of personal protective equipment:    (a)  The employer had not completed PPE hazard assessments for all production areas of the facility where 500,000 pounds of methanol was covered under process safety management and 25 pound plastic bags of sodium methylate powder were carried and loaded by hand in the palm oil interesterification process.      In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

Jun 28, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 166022609135

General-duty citation text

29 CFR 1910.132(d)(2):  The employer did not verify, through a written certification, the identity of the workplace evaluated, the person certifying that the evaluation had been performed, and the date the hazard assessment was done:    (a)  The employer had not certified in writing that an assessment had been completed to determine the hazards present in the workplace and what PPE would protect employees from those hazards, in the facility where 500,000 pounds of methanol was covered under process safety management and 25 pound plastic bags of sodium methylate powder were carried and loaded by hand in the palm oil interesterification process.      In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

Jun 13, 2013

Penalty

Initial $4,900 · Current $4,900

Hazardous substances 166022609135

General-duty citation text

29 CFR 1910.134(e)(1): The employer did not provide a medical evaluation to determine the employee's ability to use a respirator, before the employee was fit tested or required to use the respirator in the workplace:     (a)  Since April 1, 2009 and continuing through the present, the employer had not provided medical evaluations beyond the completion of the OSHA Respirator Questionnaire, even when the physician or other licensed health care professional (PLHCP) had requested further medical evaluation for employees who were required to wear respirators while working with 500,000 pounds of methanol and/or with sodium methylate powder in 25 pound bags that was carried and loaded by hand into the hopper for the palm oil esterification process.      In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

Jun 14, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 166022609135

General-duty citation text

29 CFR 1910.134(e)(3)(i): The employer did not provide a follow-up medical examination for employees who gave a positive response to any question among questions 1 through 8 in Section 2, Part A of Appendix C, or whose initial medical evaluation demonstrated a need for a follow-up medical examination:      (a)  Six employees who wore respirators as required by the employer had completed the OSHA Respirator Questionnaire in December 2012, but did not receive a medical examination and pulmonary function test as requested by the PLHCP on December 7, 2012, in order to be declared medically able to wear the respirator(s) necessary to perform their job tasks.      (b)  One employee who wore respirators as required by the employer had completed the OSHA Respirator Questionnaire on April 1, 2009, but did not receive a medical evaluation or pulmonary function test as requested by the PLHCP on April 1, 2009 in order to be declared medically able to wear the respirator(s) necessary to perform their job tasks.  On or about April 5, 2013, this employee was reported by the employer to still be wearing a respirator and had not been provided with a medical evaluation since April 1, 2009.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

Jun 14, 2013

Penalty

Initial $3,570 · Current $0 Reduced

Hazardous substances 166022609135

General-duty citation text

29 CFR 1910.134(f)(2): The employer did not ensure that an employee using a tight-fitting facepiece respirator was fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter.    (a) The employer had not provided fit tests for employees who were required to wear tight fitting full and half face respirators in the sodium methylate powder carrying and dumping tasks of the palm oil production process since one employee had been fit tested June 23, 2009.      In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.

Issued

Apr 16, 2013

Abate by

Jun 28, 2013

Penalty

Initial $4,900 · Current $2,500 Reduced

Hazardous substances 166022609135

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:    On or about December 3, 2012 the employer had not performed periodic inspections of the LO/TO program to ensure employees were following proper procedures when locking out sources of energy, such as steam, hot oil products, methanol, electricity, nitrogen and compressed air.      (a)  The employer did not conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard were being followed.    (b)  The periodic inspection was not performed by an authorized employee other than the ones(s) utilizing the energy control procedure being inspected.    (c)  The periodic inspection was not conducted to correct any deviations or inadequacies identified.    (d)  Where lockout was used for energy control, the periodic inspection did not include a review, between the inspector and each authorized employee, of that employee's responsibilities under the energy control procedure being inspected.    (e)  Where tagout was used for energy control, the periodic inspection did not include a review, between the inspector and each authorized and affected employee, of that employee's responsibilities under the energy control procedure being inspected, and the elements set forth in paragraph (c)(7)(ii) of this section.    (f) The employer did not certify that the periodic inspections had been performed by identifying the machine or equipment on which the energy control procedure was being utilized, the date of the inspection, the employees included in the inspection, and the person performing the inspection.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence, or written records.