OSHA Inspection: FLO CHEMICAL CORPORATION

Issued

Jul 9, 2013

Abate by

Dec 31, 2013

Penalty

Initial $2,000 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.38(d): The employer did not have and maintain an employee alarm system with a distinctive signal for each purpose:  **********************    a)  The employer did not have an employee alarm or intercom system capable of alerting employees in all areas of the plant including the basement area and in back rooms in the event of a fire or other emergencies which require immediate action such as evacuation.

Issued

Jul 9, 2013

Abate by

Jul 26, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.38(f)(1): The employer did not review the emergency action plan with each employee when  the employee was assigned initially to a job:  ********************   a)   The employer did not review the companys emergency action plan with the maintenance employee(s).

Issued

Jul 9, 2013

Abate by

Aug 30, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(n):  The employer's emergency action plan did not include procedures for handling small releases.    **************************    a)  The employer's Emergency Action Plan did not contain any information on how the company will handle small releases of ethanol and hydrochloric acid.  The plan did not contain information on the approximate size of a spill which would define a small release.  There were no provisions providing guidance for safely approaching small releases, such as monitoring of ethanol vapor concentrations, monitoring of Lower Explosive Limit (LEL) levels, spill containment kits and systems, and use of personal protective equipment.

Issued

Jul 9, 2013

Abate by

Oct 15, 2013

Penalty

Initial $2,800 · Current $1,000 Reduced

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.  ************************    a)  WFE Vessel, Production Room: Flexible plastic hosing is used to transport heated ethanol solutions at high flow rates to the condenser and then to downstream recycled alcohol storage tanks.  The employer had not documented that the plastic hosing is compliant with recognized and generally accepted good engineering practices for this purpose.  ****************************      b)  First Reactor and Decanting Centrifuge, Production Room:   Flexible plastic hosing is used to transport warm ethanol solutions at high flow rates.  The employer had not documented that the plastic hosing is compliant with recognized and generally accepted good engineering practices for this purpose.  *****************************      c)   VR 2 Alcohol Vapor Recovery Hose, Production Room:   The flexible plastic alcohol vapor recovery hose was attached to the steel duct with adhesive.  The employer had not documented that this method of attachment for the plastic hosing is compliant with recognized and generally accepted good engineering practices for this purpose.

Issued

Jul 9, 2013

Abate by

Dec 31, 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 Process Hazard Analysis findings; document what actions were taken; and complete actions as soon as possible.  ***********************   a)  The Process Hazard Analysis states that a necessary safeguard to alert for escaping ethanol vapors from the Rotary Vacuum Dryers (the Gluten Dryers) is the installation of an ethanol vapor monitor and alarm. The employer did not address that finding and did not document what actions were taken in regard to that finding.  ********************      b)  The Process Hazard Analysis states that a necessary safeguard to alert for escaping flammable vapors into the Production Room is the installation of an LEL Sensor.  The employer did not address that finding and did not document what actions were taken in regard to that finding.  *********************      c)  The Process Hazard Analysis states that a necessary safeguard to mitigate leaks and spills of hydrochloric acid solutions at the 1500 gallon Heavy Zein Tank (Tallboy) is the provision of acid spill kits.  The employer did not address that finding and did not document what actions were taken in regard to that finding.  *******************      d)  The Process Hazard Analysis states that a necessary safeguard for the prevention of tank ruptures at the First Reactor Tank is to implement mechanical integrity testing (ultrasound tests). The employer did not address that finding and did not document what actions were taken in regard to that finding.  ****************      e)  The Process Hazard Analysis states that a necessary safeguard for the prevention of leaks and spills of ethanol-containing solutions at the WFE vessel and at the VR 1 and VR 2 Tanks are the implementation of a Mechanical Integrity Program to prevent failures of pipe, hose, and tube connections and to detect cracks in pipes, hoses, and tubes.   The employer did not address that finding and did not document what actions were taken in regard to that finding.  ******************      f)  The Process Hazard Analysis states that a necessary safeguard for the prevention of  spills, fires, and explosions at the Alcohol Dehydration System and the VR 1 and VR 2 Tanks is the implementation of pre-start-up checklists.  The employer did not address that finding and did not document what actions were taken in regard to that finding.

Issued

Jul 9, 2013

Abate by

Oct 15, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(i): Inspections and tests were not performed on process equipment.    *****************************    a)  First Reactor, Production Room:  The employer had not performed any integrity testing, such as ultrasound testing, on the walls of the reactor.    ***********************  b)  Production Room:  The employer had not performed any testing for proper operation on the high temperature/steam shut-off valves on the First Reactor and the VR 1 and VR 2 tanks.    ********************  c)  Production Room:  Routine inspections had not been done to ensure that the plastic hose on the VR 2 tank's alcohol vapor recovery system were intact and securely connected to ductwork.

Issued

Jul 9, 2013

Abate by

Aug 11, 2013

Penalty

Initial $2,800 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(2): Operating procedures were not readily accessible to employees who work in or maintain a hazardous process.    ************************    a)  The operating procedures (the company's Chemical Procedure Manual) were not available to employees working in the Production Room for employees to reference when needed.

Issued

Jul 9, 2013

Abate by

Aug 11, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(g)(1)(i):  Employees were not trained in the operating procedures applicable to covered processes before being assigned to work at those processes.  Training shall include specific safety and health hazards, emergency shutdown, and safe work practices.   *******************  a)  Maintenance employee(s) were not given training in the company's Chemical Procedure Manual before being assigned to work in the Production Room.  Their training did not include specific safety hazards and emergency shutdown procedures.

Issued

Jul 9, 2013

Abate by

Aug 11, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(g)(3): 29 CFR 1910.119(g)(3):  The employer did not maintain a record of training for employees operating a process covered by this standard.  ************************   a)  The employer did not have records documenting that Production employees had received training in the Operating Procedures (the company's Chemical Procedure Manual) of the Zein Extraction Process.

Issued

Jul 9, 2013

Abate by

Jul 19, 2013

Penalty

Initial $2,000 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(k)(1): The employer did not issue a hot work permit for hot work operations conducted on or near a process covered by this standard:    ***************     a)  Production Room:  Welding was done on Reactor #1 on 1/18/2013, which when it is operating contains 8540 lbs. of ethanol and is part of the process covered by the Process Safety Management standard.  A hot work permit was not issued for these welding repairs to the reactor.

Issued

Jul 9, 2013

Abate by

Aug 11, 2013

Penalty

Initial $2,000 · Current $1,000 Reduced

Hazardous substances 1430

General-duty citation text

29 CFR 1910.134(d)(3)(iii)(B)(2):  The employer did not implement a change schedule for respirator cartridges that will ensure that cartridges are changed before the end of their service life.  ***************    a).  Acid Solution Room:   An employee was using a MSA full face-piece respirator equipped with cartridges that were first put in service on 3/24/2011.  The cartridges, used for protection against excessive exposure to acid mists and vapors during the hydrochloric acid dilution operation, had not been changed in more than 2 years and were past the end of their service life.

Issued

Jul 9, 2013

Abate by

Aug 30, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1430

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 the initial use of the respirator and at least annually thereafter.    *****************************    a)   Acid Solution Room:  An employee using a MSA full face-piece respirator had not been fit tested to this tight-fitting respirator.

Issued

Jul 9, 2013

Abate by

Sep 10, 2013

Penalty

Initial $2,000 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.146(d)(4)(ii):   The employer did not provide and ensure the proper use of ventilating equipment needed to obtain acceptable entry conditions.  *****************************      a)  First Reactor, Production Room:  A maintenance man entered into the First Reactor to fix the agitator.  The employer did not provide mechanical ventilation equipment.

Issued

Jul 9, 2013

Abate by

Aug 11, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.146(d)(4)(viii):    The employer did not provide and ensure the proper use of rescue and emergency equipment for employees entering permit-required confined spaces.  ********************                                          a)   First Reactor,  Production Room:  A maintenance man entered into the First Reactor to fix the agitator.  The employer did not provide an overhead winch capable of extracting the employee in the event of an emergency.

Issued

Jul 9, 2013

Abate by

Sep 10, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.146(d)(5)(i):   Before confined space entry began, air testing to determine if acceptable entry conditions existed, was not done. **********************    a)  First Reactor, Production Room:  A Maintenance man descended into the First Reactor to fix the agitator.  Air monitoring was not done to determine if the atmosphere was safe to breath.

Issued

Jul 9, 2013

Abate by

Aug 11, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.146(e)(1):   The employer did not document the completion of all the safety measures required by paragraph (d)(3) of this section by ensuring the preparation of a confined space entry permit before entry is authorized.   **************************************    a).   First Reactor, Production Room:  A Maintenance man descended into the First Reactor to fix the agitator.   Entry was performed into this designated permit-required confined space without the completion of a confined space entry permit.

Issued

Jul 9, 2013

Abate by

Aug 11, 2013

Penalty

Initial $2,000 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.219(d)(1):  Pulleys with parts seven feet or less from the floor or work platform were not guarded:    **************************     a)   Production Room: The pulleys attached to the drive motor and the screw auger at the Zein Hammer Mill were not guarded.

Issued

Jul 9, 2013

Abate by

Oct 8, 2013

Penalty

Initial $4,000 · Current $3,000 Reduced

Hazardous substances 1430

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 required to use the respirator in the workplace:  *************************     a).  Acid Solution Room:  An employee used a MSA full face-piece respirator to protect against excessive exposure to hydrochloric acid vapor when mixing the hydrochloric acid with water.  The employee was not provided with a medical evaluation to ascertain whether he can safely use a respirator without placing an undue physiological burden on his health.   ***********************     Flo Chemical Corp. was previously cited for a violation of this occupational safety and health standard which was contained in OSHA Inspection Number 313203887, Citation Number 1, Item Number 9, issued on 05/19/2010, which became a final order on 06/14/2010.