OSHA Inspection: SYNTECH CHEMICALS INC.

Issued

Jan 22, 2014

Abate by

Jan 9, 2015

Penalty

Initial $2,800 · Current $1,400 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): The employer failed to document information partaining to the process and did not include relief system design and design basis;    Instance a)  This violation was observed on or about July 31, 2013 when the employer did not ensure the process safety information (PSI) for the pressure relief valve (PSV) on 6000Rx Reactor documented and maintained; including but not limited to the calculations for relief valve sizing design and design basis.      Instance b)  This violation was observed on or about July 31, 2013 when the employer did not ensure the process safety information (PSI) for the pressure relief valve (PSV) on 7000Rx Reactor documented and maintained; including but not limited to the calculations for relief valve sizing design and design basis.

Issued

Jan 22, 2014

Abate by

Jan 9, 2015

Penalty

Initial $2,800 · Current $2,800

General-duty citation text

29 CFR 1910.119(e)(3)(i): The Process Hazards Analysis did not address the hazards of the process;                                                     -Alternative Citation-                                    29 CFR 1910.119(e)(1): The process hazard analysis was not appropriate to the complexity of the process anddid not identify, evaluate, and control the hazards involved in the process.      Instance a)  This violation was observed on or about July 31, 2013 at Syntech Chemicals when the employer did not identify and evaluate the hazards of the DMSS process that were introduced by the atmospheric discharge from the 6000Rx Pressure Relief Valve.     Instance b)  This violation was observed on or about July 31, 2013 at Syntech Chemicals when the employer did not identify and evaluate the hazards involved in the Triazine process that were introduced by the atmospheric discharge from the 7000Rx reactor Pressure Relief Valve.

Issued

Jan 22, 2014

Abate by

Jan 9, 2015

Penalty

Initial $2,800 · Current $1,400 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(ii): The employer did not develope and impliment operating limits:     (A) Consequences of deviation; and  (B) Steps required to correct or avoid deviation.      This violation was observed on or about July 31, 2013 when the employer failed to document the normal operating limits, the consequences and steps required to correct deviations from Normal Operating Limits; such as but not limited to the Normal Operating Limits for pressure and temperature, the consequences and steps required to correct deviations from Normal Operating Limits (NOP) for the DMSS process.

Issued

Jan 22, 2014

Abate by

Jan 9, 2015

Penalty

Initial $2,800 · Current $1,400 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment.    Instance a)  This violation was observed on or about July 31, 2013 at Syntech Chemicals when the employer did not establish and implement procedures for periodic inspection and testing on process equipment, including but not limited to inspection tasks and frequency intervals for 7000Rx vessel, associated piping and relief valve.    Instance b)  This violation was observed on or about July 31, 2013 at Syntech Chemicals when the employer did not establish and implement procedures for periodic inspection and testing on process equipment, including but not limited to inspection tasks and frequency intervals for 4000Rx vessel, associated piping and relief valve.

Issued

Jan 22, 2014

Abate by

Jan 9, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(ii): Inspection and testing procedures did not follow recognized and generally accepted good engineering practices.     Instance a)  This violation was observed on or about July 31, 2013 at Syntech Chemicals when the employer did not follow recognized and generally accepted good engineering practice (RAGAGEP) for inspection and testing procedures of Pressure Relief Valves (PRV), when the employer failed to perform inspection on the 7000Rx PRV.       Instance b)  This violation was observed on or about July 31, 2013 at Syntech Chemicals when the employer did not follow recognized and generally accepted good engineering practice (RAGAGEP) for inspection and testing procedures of Pressure Vessel, when the employer failed to perform inspection on the 7000Rx Reactor.       Instance c)  This violation was observed on or about July 31, 2013 at Syntech Chemicals when the employer did not follow recognized and generally accepted good engineering practice (RAGAGEP) for inspection and testing procedures of piping, when the employer failed to perform inspection on the 7000Rx Unit piping (12"P-1023; 4"P-1045; 6"P-1030 and 2P-1033).

Issued

Jan 22, 2014

Abate by

Jan 9, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(iv): The employer did not document each inspection and test that had been performed on process equipment. The documentation did not identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.    This violation was observed on or about July 31, 2013 when the employer failed to properly document the 2002 inspection and test that were performed on the Triazine 7000 Rx reactor and its associated piping (4"P-1045, 12"P-1023, 6"P-1030, and 2"P-1033). The inspection and test records did not identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.

Issued

Jan 22, 2014

Abate by

Jan 9, 2015

Penalty

Initial $2,800 · Current $1,400 Reduced

General-duty citation text

29 CFR 1910.119(l)(4): When a change resulted in a change in the process safety information required by paragraph (d) of this section, such information was not updated accordingly.    This violation was observed on or about July 31, 2013 at Syntech Chemicals, Inc. when the employer did not ensure the process safety information (PSI) for the DMSS 6000Rx Unit; including but not limited to Piping & Instrument Diagrams are updated when new equipment 6000 Rx reactor and Condenser (E-420) was added to the facility.

Issued

Jan 22, 2014

Abate by

Jan 9, 2015

Penalty

Initial $400 · Current $400

General-duty citation text

29 CFR 1910.119(i)(2)(ii): The pre-startup Safety Review Safety did not confirm that prior to the introduction of highly hazardous chemicals to a process: operating, maintenance, and emergency procedures were in place and were adequate;    This violation was observed on or about July 31, 2013 when the employer did not ensure the DMSS Standard Operating Procedure updated prior to the introduction of highly hazardous chemicals to the new equipment 6000Rx Reactor and E-420 Condenser.

Issued

Jan 22, 2014

Abate by

Jan 9, 2015

Penalty

Initial $400 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(5): Equipment deficiencies. The employer did not correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation.    The employer operated deficient process equipment such as but not limited to process piping without taking necessary means to assure safe operation. This violation was observed on or about July 31, 2013 when the employer operated DMSS process piping without being adequately.