OSHA Inspection: ACTION MANUFACTURING COMPANY

Issued

Sep 12, 2013

Abate by

Oct 16, 2013

Penalty

Initial $4,500 · Current $3,375 Reduced

General-duty citation text

29 CFR 1910.119(e)(1): The process hazard analysis was not appropriate to the complexity of the process:       (a)  Action Manufacturing Company, Atglen, Pa-  The employer performed processes to manufacture four different types of explosive products at the facility as well as associated processes for handling explosive powders, explosive pellets and blending and mixing explosive ingredients.  In December 1998 a Process Hazard Analysis (PHA) (hazard evaluation) was performed identifying the hazards within the plant and the associated areas in which they were performed.  There were no PHAs performed for the specific processes covered by this standard that were identified by this effort in a March 2000 report by Safety Management Services (SMS 98-0069).  Conditions observed on or about May 2, 2013.       NOTE:  Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 12, 2013

Abate by

Oct 16, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(6): The process hazard analysis was not updated and revalidated every five years:   a) Action Manufacturing Company, Atglen, PA-  The employer performed an initial Process Hazard Analysis in December 1998 and possessed a March, 2000 report prepared by Safety Management Systems (SMS 98-0069).  There are no updates or revalidations to the PHA which was intended to address all of the explosive manufacturing processes in the facility.  Conditions observed on or about May 2, 2013.      NOTE:  Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 12, 2013

Abate by

Oct 16, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the PHA team's findings and recommendations, to assure the recommendations were resolved in a timely manner, and to assure the resolutions were documented:     a) Action Manufacturing Company, Atglen, PA-  The employer performed an initial Process Hazard Analysis in December 1998 and possessed a March, 2000 report prepared by Safety Management Systems (SMS 98-0069).  Table 1 Hazard Analysis Recommendations for Action Manufacturing enumerates 37 Operations/Items each having multiple recommendations.   Safety Action Requests dated 22 February 2011 list the majority of the recommendations as "O" for open.  Those recommendations listed as "I" for implemented are not supported with the documented resolution.  Conditions observed on or about May 2, 2013.   NOTE:  Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 12, 2013

Abate by

Oct 1, 2013

Penalty

Initial $4,500 · Current $3,375 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)  Action Manufacturing Company, Atglen, PA-  The employer did not develop a written plan of action to consult with employees on the conduct and development of information required by the Process Safety Management Standard.  Observed on or about May 2, 2013.

Issued

Sep 12, 2013

Abate by

Oct 16, 2013

Penalty

Initial $4,500 · Current $3,375 Reduced

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:       a)  Action Manufacturing Company, Atglen, PA-  The employer performed an initial Process Hazard Analysis in December 1998 and possessed a March, 2000 report prepared by Safety Management Systems (SMS 98-0069).  There were no written procedures to manage change developed to address changes that could effect explosives manufacturing processes in the facility.  Observed on or about May 2, 2013.          NOTE:  Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 12, 2013

Abate by

Oct 16, 2013

Penalty

Initial $4,500 · Current $3,375 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not evaluate compliance with the provisions of 29 CFR 1910.119 Process Safety Management, at least every three years, to verify that the procedures and practices developed under the standard were adequate and being followed:       a) Action Manufacturing Company, Atglen, PA-  The employer performed an initial Process Hazard Analysis in December 1998 and possessed a March, 2000 report prepared by Safety Management Systems (SMS 98-0069).  There were no compliance audits performed to verify that procedures and practices developed under the standard were developed and being followed.  Observed on or about May 2, 2013.      NOTE:  Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.