OSHA Inspection: BLICK'S PHOSPHATE CONVERSIONS, LLC

Issued

2013-09-06 00:00:00

Abate by

2013-10-02 00:00:00

Penalty

Initial $7000.00 · Current $5000.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(d)(2)(i)(E): Information concerning the technology of the process did not include an evaluation of the consequences of deviations, including those affecting the safety and health of employees.  (a)  Ammonium Polyphosphate Portable Pipe Reactor, on or about May 18, 2013, and at times prior thereto, the employer did not identify and document the consequences of deviations from the manufacturing process parameters, including but not limited to, deviations from process temperature, pressure, and reactants composition and flow rates.    Note:  Abatement certification and documentation are required for this item.

Issued

2013-09-06 00:00:00

Abate by

2013-10-02 00:00:00

Penalty

Initial $7000.00 · Current $6000.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(e)(3)(iii):  The process hazard analysis did not address engineering and administrative controls applicable to the hazards and their interrelationships.                       (a)  Ammonium Polyphosphate Portable Pipe Reactor, on or about May 18, 2013, and at times prior thereto, the facility's process hazard analysis was deficient in that it did not identify and provide controls such as, but not limited to, ammonia detection and alarm devices; interlocking devices; and/or check valves to prevent the inadvertent mixing of ammonia and water during a process start-up.  Note:  Abatement certification and documentation are required for this item.

Issued

2013-09-06 00:00:00

Abate by

2013-10-02 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not address human factors:    (a)  Ammonium Polyphosphate Portable Pipe Reactor, on or about May 18, 2013, and at times prior thereto, the  process hazard analysis did not address the hazards caused by operating the system while the water flush valve is open.   The reactor operator, on May 18, 2013, started the flow of anhydrous ammonia without closing the water flush valve and opening the water lines to the reactor, allowing an exothermic reaction to occur, a PVC valve to fail, and an exposure to skin burns and a toxic atmosphere.    Note:  Abatement certification and documentation are required for this item.

Issued

2013-09-06 00:00:00

Abate by

2013-10-02 00:00:00

Penalty

Initial $7000.00 · Current $5000.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(f)(1)(iii):  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 the process safety information and did not address at least the safety and health considerations:  (a)  Ammonium Polyphosphate Portable Pipe Reactor, on or about May 18, 2013, and at times prior thereto, Emergency Shut Down Procedures and Startup Procedures Following Emergency Shut Down did not address safety and health considerations such as, but not limited to, properties of, and hazards presented by, the chemicals used in the process (like exothermic reactions between ammonia and water); precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment (like buddy system for start-up, PPE worn during start-up); control measures to be taken if physical contact or airborne exposure occurs (like isolating the control room from piping valves); and any special or unique hazards (like unexpected shutdown requests).  Note:  Abatement certification and documentation are required for this item.