OSHA Inspection: THE GILMAN BROTHERS COMPANY

Issued

Nov 27, 2013

Abate by

Dec 31, 2014

Penalty

Initial $5,390 · Current $5,390

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams did not include information that provided specific identification of equipment that is part of the process:      A.  On or about May 31, 2013, Facility:  The employer's piping and instrumentation diagrams did not include information, such as, but not limited to:  The set pressure for the pressure relief valves installed on the 18,000-gallon isopentane vessel or the pressure relief valves at the Corken pumps, the maximum allowable working pressure on the isopentane vessel, and documentation of the pressure relief stacks provided.

Issued

Nov 27, 2013

Abate by

Dec 31, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): The employer did not include, in the process safety information compilation, the relief system design and the design basis:      A.  On or about May 31, 2013, Facility:  The process safety information maintained by the employer did not include information on the relief system design basis for the two Fisher H282-250 Series Large Internal Spring Relief Valves installed on the isopentane vessel and the two Corken B166 pressure relief valves.

Issued

Nov 27, 2013

Abate by

Dec 31, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F): Design codes and standards pertaining to the equipment in the process were not compiled before conducting any process safety analysis required by this standard:      A.  On or about May 31, 2013, Facility:  The employer had not documented the design codes employed in designing the pressure relief system for the process using isopentane as a blowing agent.

Issued

Nov 27, 2013

Abate by

Dec 31, 2014

Penalty

Initial $3,850 · Current $3,850

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.  On or about May 31, 2013, Facility:  The employer did not comply with a RAGAGEP, such as, but not limited to ASME Boiler and Pressure Vessel Code, Section VIII or API 520, in that:    1.  The employer did not document the inlet pressure drop for pressure relief valves used to protect the pressure vessel containing isopentane.    2.  The employer did not document the built up back pressure of the pressure relief valves used to protect the pressure vessel containing isopentane.

Issued

Nov 27, 2013

Abate by

Mar 31, 2015

Penalty

Initial $5,390 · Current $5,390

General-duty citation text

29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not consider consequences of failure of engineering and administrative controls:      A.  On or about May 31, 2013, Facility:  The process hazard analysis provided by the employer did not take into consideration the consequences of failure of engineering and administrative controls, such as, but not limited to, failure of Drager gas detection system.

Issued

Nov 27, 2013

Abate by

Mar 31, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting:      A.  On or about May 31, 2013, Facility:  The employer did not consider the effects an overpressure and rupture of the pressure vessel of isopentane would have on the occupied structures on the site.

Issued

Nov 27, 2013

Abate by

Mar 31, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not address human factors:      A.  On or about May 31, 2013, Facility:  The company's process hazard analysis did not consider the following:    1.  Shift changes and the circumstances that could effect processes, such as the maintenance of covered equipment.    2.  Employee fatigue, as the employer operates the covered process on a 3-shift schedule.

Issued

Nov 27, 2013

Abate by

Mar 3, 2014

Penalty

Initial $3,850 · Current $3,850

General-duty citation text

29 CFR 1910.119(f)(3): The employer did not annually certify that operating procedures were current and accurate:        A.  On or about May 31, 2013, Facility:  The employer had not reviewed written operating procedures annually, including, but not limited to the following:    1.  The operating procedure for receiving isopentane, File #PP-740, was dated October 20, 2005 and had not been reviewed annually.    2.  The company's Emergency Action Plan, File #PP-887-02, was dated January 19, 2011 and had not been reviewed within the past year.  The Emergency Action Plan included emergency shut down procedures for process equipment.

Issued

Nov 27, 2013

Abate by

Dec 31, 2014

Penalty

Initial $53,900 · Current $26,796 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:      A.  On or about May 31, 2013, Facility:  The employer had not performed inspections and tests on process equipment, including, but not limited to:  Pressure vessels; piping systems; valves; relief and vent systems and devices; emergency shutdown systems; monitoring devices and sensors; alarms; interlocks; and pumps used in the process where isopentane was used as a blowing agent.

Issued

Nov 27, 2013

Abate by

Dec 31, 2014

Penalty

Initial $10,780 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment:      A.  On or about May 31, 2013, Facility:  The employer had not developed and implemented specific written procedures to address regular inspections and preventive maintenance to covered processes in accordance with recognized and generally accepted good engineering practices.  The procedures would need to cover tanks, pumps, piping and process equipment used for the foam board production line that used isopentane as a blowing agent.    The Gilman Brothers Company was previously cited for a violation of this Occupational Safety and Health standard or its equivalent standard (1910.119(j)(2)), which was contained in OSHA inspection number 311759021, Citation Number 1, Item Number 10a and was affirmed as a final order on March 16, 2009, with respect to a workplace located at Gilman Road, Gilman, Connecticut.