OSHA Inspection: DPT LABORATORIES LTD

Issued

2013-10-30 00:00:00

Penalty

Initial $3000.00 · Current $1500.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(C): Information pertaining to the equipment in the process did not include the electrical classification:    The employer does not ensure that process safety information includes an electrical classification.  The violation occurred on or about June 18, 2013, and at times prior thereto in the aerosol process line where the employer failed to ensure that the process safety information included the electrical classification aerosol process. This condition exposed employees to fire and explosion hazards.      Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement date the employer must submit documentation showing that it is in compliance with the standard, including ensuring process safety information includes electrical classification.

Issued

2013-10-30 00:00:00

Abate by

2013-11-14 00:00:00

Penalty

Initial $3000.00 · Current $1500.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to assure that the recommendations were resolved in a timely manner and that the resolution was documented; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.    The employer did not develop a written schedule as to when the actions recommended by the process hazard analysis team are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.      The employer does not ensure that a written schedule is developed for the completion of action items resulting from the process hazard analysis.  The violation occurred on or about June 18, 2013 and at times prior thereto in the aerosol process line where the employer failed to ensure that a written schedule is developed for the completion of the action items and/or finding from the 2009 PHA.  This includes but is not limited to the following action item:      a.     #09-01:  Link safe work practice with SOPs, where a responsible person was assigned to the task with a due date 3/31/2009.      This condition exposed employees to fire and explosion hazards associated with a flammable liquid and/or vapor release.      Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement date the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking to ensure that a written schedule is completed for action items resulting from process hazards analysis.

Issued

2013-10-30 00:00:00

Abate by

2013-11-14 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected:    The employer does not ensure that an appropriate and prompt response to each of the findings of the compliance audit.  The violation occurred on or about June 18, 2013 and at times prior thereto in the aerosol process line where the employer failed to ensure a prompt and an appropriate response was documented for audit findings from the 2007 and 2008 Process Safety Compliance audit items such as but not limited to:      a.  2007 finding #19 Operating procedures  b.  2007 finding #33 Contractor Control  c.  2007 finding #63 Compliance audits  d.  2008 finding #68 Operating Procedures  e.  2008 finding #84 Pre-Safety Start-up review  f.   2008 finding #99 Compliance audits      Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement date the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking to ensure that its process safety management compliance audits findings have been addressed and a response is documented.

Issued

2013-10-30 00:00:00

Abate by

2013-11-14 00:00:00

Penalty

Initial $3000.00 · Current $1500.00 Reduced

General-duty citation text

29 CFR 1910.119(f)(3): The employer did not annually certify that operating procedures were current and accurate.    The employer does not ensure standard operating procedures are certified annually as being current and accurate.  The violation occurred on or about June 18, 2013 and at times prior thereto in the aerosol process line where the employer failed to ensure standard operating procedures were certified annually as being current and accurate. This condition exposed employees to fire and explosion hazards.    Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing the steps it is taking to ensure standard operating procedures are certified annually as being current and accurate.

Issued

2013-10-30 00:00:00

Penalty

Initial $7000.00 · Current $5000.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish or implement written procedures to maintain the on-going integrity of process equipment:    The employer does not ensure written procedures are established and implemented to maintain the on-going mechanical integrity of the process equipment.      A. The violation occurred on or about June 18, 2013 and at times prior thereto in the aerosol process line where the employer failed to ensure that written procedures were established and implemented for the testing and inspection of the facilities AP-70 piping.      B. The violation occurred on or about June 18, 2013 and at times prior thereto in the aerosol process line where the employer failed to ensure that written procedures were established and implemented for the testing and inspection of the facilities AP-70 storage vessels. Identified vessels included but not limited TK-1323 storage tank.    C. The violation occurred on or about June 18, 2013 and at times prior thereto in the aerosol process line where the employer failed to ensure that written procedures were established and implemented for the testing and inspection of the facilities relief valves. Identified relief valves included but not limited to those on TK-1323 AP-70 storage tank.      These conditions exposed employees to fire and explosion hazards.       Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing the steps it is taking to ensure written procedures are established and implemented to maintain the on-going mechanical integrity of the process equipment.

Issued

2013-10-30 00:00:00

Penalty

Initial $7000.00 · Current $7000.00

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment.  The employer does not ensure inspection and testing is performed on process equipment.    A.  The violation occurred on or about June 18, 2013 and at times prior thereto in the aerosol process line where the employer failed to ensure the inspection and testing of process vessels. Identified vessel(s) include but are not limited to TK-1323 AP-70 storage tank.    B.  The violation occurred on or about June 18, 2013 and at times prior thereto in the aerosol process line where the employer failed to ensure perform inspection and/or replacement of relief valve(s). Identified relief valves include but are not limited to those on TK-1323 AP-70 storage tank.     C.  The violation occurred on or about June 18, 2013 and at times prior thereto in the aerosol process line where the employer failed to ensure inspection and testing was completed on process piping. Identified piping includes but is not limited to:   a.     V-904 outlet piping to V-209 fill line 1; b.     V-703 outlet piping to V-203; c.     V-905 return line to V-605.      These conditions exposed employees to fire and explosion hazards.     Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement date the employer must submit documentation showing that it is in compliance with the standard, including the description of the steps that it has taken to ensure that inspection and testing on process equipment is conducted.

Issued

2013-10-30 00:00:00

Abate by

2013-11-14 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits.   The employer does not correct deficiencies of equipment that are outside acceptable limits in a timely manner.  This violation occurred on or about June 18, 2013 and times prior thereto in the aerosol process line where the employer failed to correct deficiencies in equipment that were outside acceptable limits in a timely manner.  This includes but is not limited to relief valves V-915 and V-916 on TK-1323 AP-70 vessel. This condition exposed employees to fire and explosion hazards.    Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement date the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking to ensure that equipment deficiencies are corrected in a timely manner.

Issued

2013-10-30 00:00:00

Penalty

Initial $7000.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(ii):  Inspections and testing procedures performed on process equipment to maintain its mechanical integrity, did not follow recognized and generally accepted good engineering practices.      The employer does not ensure inspections and tests performed on process equipment to maintain its on-going mechanical integrity followed recognized and generally accepted good engineering practices (RAGAGEP).      A) The violation occurred on or about June 18, 2013 and at times prior thereto in the aerosol process line where the employer failed to ensure inspection and tests of process vessel followed RAGAGEP such as API 510. Identified equipment include but is not limited to TK-1323;    B) The violation occurred on or about June 18, 2013 and at times prior thereto in the aerosol process line where the employer failed to ensure inspection and tests of process piping followed RAGAGEP such as API 570. Identified equipment include but is not limited to the following:    a. V-904 outlet piping to V-209 fill line 1;  b. V-703 outlet piping to V-203;  c. V-905 return line to V-605.      This condition exposed employees to fire and explosion hazards.      Pursuant to 29 C.F.R. 1903.19, within ten (10) calendar days of the abatement date the employer must submit documentation showing it is in compliance with the standard, including describing the steps it is taking to ensure inspections and tests performed on process equipment to maintain its on-going mechanical integrity followed recognized and generally accepted good engineering practices.

Issued

2013-10-30 00:00:00

Abate by

2013-11-14 00:00:00

Penalty

Initial $4000.00 · Current $2000.00 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not certify that they had evaluated compliance with provisions of 29 CFR 1910.119 at least every three years to verify that the procedures and practices developed under this standard were adequate and are being followed:      The employer does not ensure compliance with provisions of 29 CFR 1910.119 at least every three years to verify that the procedures and practices developed under this standard were adequate.  The violation occurred on or about June 18, 2013 and at times prior thereto where the employer failed to ensure that it completed an evaluation of compliance with the process safety management standard exposing employees to fire and explosion hazards from releases of liquid and/or flammable vapors.     Pursuant to 29 C.F.R. 1903.19, within (10) calendar days of the abatement date the employer must submit documentation showing that it is in compliance with the standard, including describing the steps that it is taking to ensure that its process safety management compliance audits are completed at least every three years.