OSHA Inspection: CAROL CALLAHAN

Issued

Feb 6, 2014

Penalty

Initial $3,500 · Current $2,940 Reduced

General-duty citation text

29 CFR 1910.106(d)(4)(i): "Construction." Inside storage rooms were not constructed so that openings to other rooms or buildings were provided with noncombustible liquid-tight raised sills or ramps at least 4 inches in height, or the floor in the storage area were not at least 4 inches below the surrounding floor and the openings were not provided with approved self-closing fire doors. The inside storage room did not have a permissible alternate to the sill or ramp, open-grated trench inside of the room which drains to a safe location:    a) The employer does not ensure that inside flammable storage rooms are constructed so that the openings have either raised sills or ramps, lowered floors, or an open-grated trench which drains to a safe location.  This violation occurred when a storage room without the required construction features, inside production lab PP-M, was used to store flammable liquids (hexane, acetone, and isopropyl alcohol).

Issued

Feb 6, 2014

Penalty

Initial $3,500 · Current $0 Reduced

Hazardous substances 004013801560

General-duty citation text

29 CFR 1910.106(d)(4)(iii): Electrical wiring and equipment located in inside storage rooms used for Category 1 or 2 flammable liquids, or Category 3 flammable liquids with a flashpoint below 100  deg.F (37 deg.C), was not approved under subpart S of this part for Class I, Division 2 Hazardous Locations:     a) The employer does not ensure that the electrical wiring and equipment located inside storage rooms used for Category 2 flammable liquids was not approved under subpart S of this part for Class I, Division 2 Hazardous locations.  This violation occurred when three Category 2 flammable liquids (hexane, acetone, and isopropyl alcohol) were stored in the inside storage room of production lab PP-M.

Issued

Feb 6, 2014

Penalty

Initial $4,900 · Current $0 Reduced

Hazardous substances 004013801560

General-duty citation text

29 CFR 1910.106(d)(4)(v): "Storage in inside storage rooms." In every inside storage room, dispensing was not by approved pump or self-closing faucet only:  a) The employer does not ensure that flammable liquids in an inside storage room are dispensed by an approved pump or self-closing faucet.  This violation occurred when employees were allowed to dispense Category 2 flammable liquids (hexane, acetone and isopropyl alcohol) from plastic containers with manually actuated valves and gravity flow.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $4,900 · Current $3,920 Reduced

Hazardous substances 00400060104010601380

General-duty citation text

29 CFR 1910.106(d)(7)(iv): Materials which will react with water were stored in the same room with flammable liquids:  a) The employer allowed water-reactive chemicals to be stored with flammable liquids.  This violation occurred when the employer allowed a water-reactive chemical (phosphorus pentasulfide) to be stored with numerous flammable liquids in the Drum Storage Shed.   b) The employer allowed water-reactive chemicals to be stored with flammable liquids.  This violation occurred when the employer allowed a water-reactive chemical (butyryl chloride) to be stored with numerous flammable liquids in the Drum Storage Shed.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $4,900 · Current $3,920 Reduced

Hazardous substances 0170138016432460

General-duty citation text

29 CFR 1910.106(h)(3)(iii)(b): Equipment used in a building and the ventilation of the building was not designed so as to limit flammable vapor-air mixtures under normal operating conditions to the interior of equipment:  a) The employer does not ensure that equipment used in a building is designed so as to limit the flammable vapor-air mixtures under normal operating conditions to the interior of the equipment.  This violation occurred in the production lab PP-1, when employees used glassware, equipment and other containers for producing products using flammable liquids that allowed flammable vapor-air mixtures to vent from the openings.  b) The employer does not ensure that equipment used in a building is designed so as to limit the flammable vapor-air mixtures under normal operating conditions to the interior of the equipment.  This violation occurred in the production lab PP-2, when employees used glassware, equipment and other containers for producing products using flammable liquids that allowed flammable vapor-air mixtures to vent from the openings.  c) The employer does not ensure that equipment used in a building is designed so as to limit the flammable vapor-air mixtures under normal operating conditions to the interior of the equipment.  This violation occurred in the production lab PP-3, when employees used glassware, equipment and other containers for producing products using flammable liquids that allowed flammable vapor-air mixtures to vent from the openings.    d) The employer does not ensure that equipment used in a building is designed so as to limit the flammable vapor-air mixtures under normal operating conditions to the interior of the equipment.  This violation occurred in the production lab PP-M, when employees used glassware, equipment and other containers for producing products using flammable liquids that allowed flammable vapor-air mixtures to vent from the openings.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $4,900 · Current $3,920 Reduced

General-duty citation text

29 CFR 1910.120(q)(1): The employer did not develop and implement an emergency response plan to handle anticipated emergencies prior to commencement of emergency response operations:  a) The employer does not ensure that an emergency response plan is developed and implemented to handle anticipated emergencies prior to the commencement of emergency response operations.  This violation occurred when employees responded to a hexane fire in laboratory PP-2 in the presence of other toxic and flammable chemicals.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $4,900 · Current $3,920 Reduced

Hazardous substances 13102168

General-duty citation text

29 CFR 1910.132(a): Protective equipment was not used when necessary whenever hazards capable of causing injury and impairment were encountered:  a) The employer does not ensure that personal protective equipment is used when hazards capable of causing injury and impairment are encountered. This violation occurred when the employer did not ensure the use of protective clothing for the legs and arms when pouring and handling corrosive materials in order to prevent burns to employees exposed skin.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $4,900 · Current $3,920 Reduced

General-duty citation text

29 CFR 1910.134(c)(3): The employer did not designate a program administrator who was qualified by appropriate training or experience to administer or oversee the respiratory protection program and to conduct the required evaluations of program effectiveness:  a) The employer does not ensure that a program administrator is designated that is qualified by appropriate training or experience to administer or oversee the respiratory protection program and to conduct the required evaluations of program effectiveness.  This violation occurred when the employer designated a program administrator that was not qualified to conduct the required evaluations of respiratory hazards and program effectiveness at the Oakdale, LA facility.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $4,900 · Current $0 Reduced

General-duty citation text

29 CFR 1910.134(d)(1)(iii): The employer did not identify and evaluate the respiratory hazard(s) in the workplace; including a reasonable estimate of employee exposures to respiratory hazards and identification of the contaminants chemical state and physical form:  a) The employer does not identify and evaluate the respiratory hazard(s) in the workplace, including a reasonable estimate of employee exposures to respiratory hazards.  This violation occurred on or about August 8, 2013 in the Oakdale, Louisiana facility when employees were manufacturing natural flavorings using a variety of hazardous chemicals, including chemicals listed in 1910.1000 Tables Z-1 and Z-2.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(d)(1)(i): Where methylene chloride was present in the workplace, the employer did not determine each employee's exposure:  a) The employer does not determine each employee's exposure to methylene chloride, where methylene chloride is present in the workplace.  This violation occurred when employees used methylene chloride in the production of flavorings.

Issued

Feb 6, 2014

Penalty

Initial $3,500 · Current $2,730 Reduced

Hazardous substances 143021682260

General-duty citation text

29 CFR 1910.151(c): Where employees were exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use:    a) The employer does not ensure that an emergency shower for quick drenching the body was available for immediate emergency use.  This violation occurred when the emergency shower on the Back Porch area of the production facility was obstructed by plastic containers of waste solvent.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $4,900 · Current $0 Reduced

Hazardous substances 00401380156016602460

General-duty citation text

29 CFR 1910.307(c): Equipment, wiring methods, and installations of equipment in hazardous (classified) locations were not intrinsically safe, approved for the hazardous (classified) location, or safe for the hazardous (classified) location:    a) The employer does not ensure equipment, wiring methods, and installations of equipment in hazardous locations are intrinsically safe, approved for the hazardous location, or safe for the hazardous location.  This violation occurred when employee were assigned to work in Laboratory PP-1 where the equipment, wiring methods, and installations (including but not limited to vacuum pumps, floor fans, bug zappers, breaker panels, electrical outlets, junction boxes, and wall fans) were not appropriate for a Class 1 Division 2 location.      b) The employer does not ensure equipment, wiring methods, and installations of equipment in hazardous locations are intrinsically safe, approved for the hazardous location, or safe for the hazardous location.  This violation occurred when employee were assigned to work in Laboratory PP-2 where the equipment, wiring methods, and installations (including but not limited to vacuum pumps, floor fans, bug zappers, breaker panels, electrical outlets, junction boxes, and wall fans) were not appropriate for a Class 1 Division 2 location.      c) The employer does not ensure equipment, wiring methods, and installations of equipment in hazardous locations are intrinsically safe, approved for the hazardous location, or safe for the hazardous location.  This violation occurred when employee were assigned to work in Laboratory PP-3 where the equipment, wiring methods, and installations (including but not limited to vacuum pumps, floor fans, bug zappers, breaker panels, electrical outlets, junction boxes, and wall fans) were not appropriate for a Class 1 Division 2 location.      d) The employer does not ensure equipment, wiring methods, and installations of equipment in hazardous locations are intrinsically safe, approved for the hazardous location, or safe for the hazardous location.  This violation occurred when employee were assigned to work in Laboratory PP-M where the equipment, wiring methods, and installations (including but not limited to vacuum pumps, floor fans, bug zappers, breaker panels, electrical outlets, junction boxes, and wall fans) were not appropriate for a Class 1 Division 2 location.      e) The employer does not ensure equipment, wiring methods, and installations of equipment in hazardous locations are intrinsically safe, approved for the hazardous location, or safe for the hazardous location.  This violation occurred when employee were assigned to work in the Drum Storage Shed where the equipment, wiring methods, and installations (including electrical outlets and installations) were not appropriate for a Class 1 Division 2 location.      f) The employer does not ensure equipment, wiring methods, and installations of equipment in hazardous locations are intrinsically safe, approved for the hazardous location, or safe for the hazardous location.  This violation occurred when employee were assigned to work on the Back Porch of the Production Area where the equipment, wiring methods, and installations (including electrical outlets and installations) were not appropriate for a Class 1 Division 2 location.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.307(d): Conduits in hazardous (classified) locations were not threaded:     a) The employer does not ensure that conduits in hazardous locations are threaded.  This violation occurred when employee were assigned to work in Laboratory PP-1 where the conduit was standard flexible metal conduit with clamped connectors.       b) The employer does not ensure that conduits in hazardous locations are threaded.  This violation occurred when employee were assigned to work in Laboratory PP-2 where the conduit was standard flexible metal conduit with clamped connectors.       c) The employer does not ensure that conduits in hazardous locations are threaded.  This violation occurred when employee were assigned to work in Laboratory PP-3 where the conduit was standard flexible metal conduit with clamped connectors.       d) The employer does not ensure that conduits in hazardous locations are threaded.  This violation occurred when employee were assigned to work in Laboratory PP-M where the conduit was standard flexible metal conduit with clamped connectors.       e) The employer does not ensure that conduits in hazardous locations are threaded.  This violation occurred when employee were assigned to work on the Back Porch of the Production Area where the conduit was standard flexible metal conduit with clamped connectors.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $7,000 · Current $5,600 Reduced

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(c)(1): The employer did not ensure that no employee(s) was exposed to an airborne concentration of methylene chloride in excess of twenty-five parts per million as an 8-hour TWA:    a)  The employer does not ensure that no employees are exposed to an airborne concentration of methylene chloride in excess of twenty-five (25) parts per million as an eight (8) hour time weighted average (TWA).  This violation occurred when an employee in Laboratory PP-3 was exposed to an eight-hour time weighted average concentration of forty-seven (47) parts per million of Methylene Chloride when sampled for 471 minutes.  Zero exposure was assumed for the un-sampled 9 minutes.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(c)(2): The employer did not ensure that no employee was exposed to an airborne concentration of methylene chloride in excess of 125 parts per million as determined over a sampling period of 15 minutes:    a) The employer does not ensure that no employees are exposed to an airborne concentration of methylene chloride in excess of one-hundred twenty-five (125) parts per million Short Term Exposure Limit (STEL).  This violation occurred when an employee in the outdoor production area was exposed to a STEL concentration of six-hundred sixty (660) parts per million of Methylene Chloride when sampled for 15 minutes.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(f)(1): The employer did not institute and maintain the effectiveness of engineering controls and work practices to reduce employee exposure to or below the permissible exposure limits and wherever the feasible engineering controls and work practices which can be instituted were not sufficient to reduce employee exposure to or below the 8-hour time weighted average permissible exposure limit or short term exposure limit, the employer did not use them to reduce employee exposure to the lowest levels achievable and did not supplement them by the use of respiratory protection that compiled with the requirements of 29 CFR 1910.1052(g):   a) The employer does not institute and maintain the effectiveness of engineering controls and work practices to reduce employee exposure to methylene chloride below the permissible exposure limits or supplement them by the use of respiratory protection that complied with the requirements of 29 CFR 1910.1052(g).  This violation occurred when an employee in Laboratory PP-3 was exposed to methylene chloride above the Permissible Exposure Limit (PEL) without effective engineering controls.  The employee was exposed to an eight-hour time weighted average concentration of forty-seven (47) parts per million of Methylene Chloride when sampled for 471 minutes.  Zero exposure was assumed for the un-sampled 9 minutes.    b) The employer does not institute and maintain the effectiveness of engineering controls and work practices to reduce employee exposure to methylene chloride below the permissible exposure limits or supplement them by the use of respiratory protection that complied with the requirements of 29 CFR 1910.1052(g).  This violation occurred when an employee in the Outdoor Production Area was exposed to methylene chloride above the Short Term Exposure Limit (STEL) without effective engineering controls.  The employee was exposed to a STEL  concentration of six-hundred sixty (660) parts per million of Methylene Chloride when sampled for 15 minutes.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(g)(1): For employees who use respirators required by 29 CFR 1910.1052, the employer did not provide each employee an appropriate respirator that complied with the requirements of 29 CFR 1910.1052(g):   a) The employer does not ensure that employees who use respirators required by 20 CFR 1910.1052 are provided with an appropriate respirator that complied with the requirements.  This violation occurred when an employee in Laboratory PP-3 was exposed to a forty-seven (47) parts per million time-weighted average (TWA) concentration of methylene chloride, above the Permissible Exposure Limit (PEL).   b) The employer does not ensure that employees who use respirators required by 20 CFR 1910.1052 are provided with an appropriate respirator that complied with the requirements.  This violation occurred when an employee in Outdoor Production Area was exposed to a six-hundred sixty (660) parts per million concentration of methylene chloride, above the Short Term Exposure Limit (STEL).

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $4,900 · Current $4,900

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(e)(1): The employer did not establish a regulated area wherever an employee's exposure to airborne concentrations of methylene chloride exceeded or could reasonably be expected to exceed either the 8-hour Time Weighted Average Permissible Exposure Limit or the Short Term Exposure Limit:   a) The employer does not ensure that a regulated area is established wherever an employee's exposure to airborne concentrations of methylene chloride exceeds or could reasonably be expected to exceed the 8-hour Time Weighted Average Permissible Exposure Limit (PEL) or the Short Term Exposure Limit (STEL).  This violation occurred when employees worked in an un-regulated area, Lab PP-3, where exposures to methylene chloride were above the PEL.  b) The employer does not ensure that a regulated area is established wherever an employee's exposure to airborne concentrations of methylene chloride exceeds or could reasonably be expected to exceed the 8-hour Time Weighted Average Permissible Exposure Limit (PEL) or the Short Term Exposure Limit (STEL).  This violation occurred when employees worked in an un-regulated area, Outdoor Production Area, where exposures to methylene chloride were above the STEL.  c) The employer does not ensure that a regulated area is established wherever an employee's exposure to airborne concentrations of methylene chloride exceeds or could reasonably be expected to exceed the 8-hour Time Weighted Average Permissible Exposure Limit (PEL) or the Short Term Exposure Limit (STEL).  This violation occurred when employees worked in an un-regulated area, Lab PP-M, where exposures to methylene chloride could reasonably be expected to exceed the 8-hour TWA or STEL.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $4,900 · Current $0 Reduced

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(f)(3)(i): The employer did not implement procedures to detect leaks of methylene chloride in the workplace:  a. The employer does not ensure that procedures to detect leaks of methylene chloride in the workplace are implemented.  This violation occurred when employees were working with methylene chloride in Laboratory PP-3 without any method to detect leaks from the system.  b. The employer does not ensure that procedures to detect leaks of methylene chloride in the workplace are implemented.  This violation occurred when employees were working with methylene chloride in the Outdoor Production Area without any method to detect leaks from the system.  c. The employer does not ensure that procedures to detect leaks of methylene chloride in the workplace are implemented.  This violation occurred when employees were working with methylene chloride in Laboratory PP-M without any method to detect leaks from the system.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $4,900 · Current $0 Reduced

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(h)(1): Where needed to prevent methylene chloride induced skin or eye irritation, the employer did not provide clean protective clothing and equipment resistant to methylene chloride, at no cost to the employee, and/or did not ensure that each affected employee used it:  a. The employer does not ensure that each affected employee uses clean protective clothing and equipment resistant to methylene chloride.  This violation occurred when employees in PP-3 did not wear chemical protective clothing resistant to methylene chloride.  b. The employer does not ensure that each affected employee uses clean protective clothing and equipment resistant to methylene chloride.  This violation occurred when employees in the Outdoor Production Area did not wear chemical protective clothing resistant to methylene chloride.    c. The employer does not ensure that each affected employee uses clean protective clothing and equipment resistant to methylene chloride.  This violation occurred when employees in PP-M did not wear chemical protective clothing resistant to methylene chloride.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $4,900 · Current $0 Reduced

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(j)(1)(i): The employer did not make medical surveillance available for employees who were or potentially were  exposed to methylene chloride at or above the action level on 30 or more days per year, or above the 8-hour time weighted average permissible exposure limit or the short term exposure limit on 10 or more days per year:  a. The employer does not ensure that medical surveillance is made available for employees who were exposed or potentially exposed to methylene chloride at or above the action level on 30 or more days per year, or above the 8-hour time weighted average permissible exposure limit or the short term exposure limit on 10 or more days per year.  This violation occurred when an employee working in Laboratory PP-3 stripping methylene chloride was exposed above the PEL.  b. The employer does not ensure that medical surveillance is made available for employees who were exposed or potentially exposed to methylene chloride at or above the action level on 30 or more days per year, or above the 8-hour time weighted average permissible exposure limit or the short term exposure limit on 10 or more days per year.  This violation occurred when an employee working in the Outdoor Production Area using methylene chloride was exposed above the STEL.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $4,900 · Current $0 Reduced

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(l)(1): The employer did not provide information and training for each affected employee prior to or at the time of initial assignment to a job involving potential exposure to methylene chloride:  a. The employer does not provide information and training for each affected employee prior to or at the time of initial assignment to a job involving potential exposure to methylene chloride.  This violation occurred when the employee in laboratory PP-3 was not given information on the requirements of the standard, the information available in the standard's appendices, and how to access a copy of the standard in the workplace.  b. The employer does not provide information and training for each affected employee prior to or at the time of initial assignment to a job involving potential exposure to methylene chloride.  This violation occurred when the employee in the Outdoor Production Area was not given information on the requirements of the standard, the information available in the standard's appendices, and how to access a copy of the standard in the workplace.  c. The employer does not provide information and training for each affected employee prior to or at the time of initial assignment to a job involving potential exposure to methylene chloride.  This violation occurred when the employee in laboratory PP-M was not given information on the requirements of the standard, the information available in the standard's appendices, and how to access a copy of the standard in the workplace.

Issued

Feb 6, 2014

Abate by

Feb 14, 2014

Penalty

Initial $4,900 · Current $3,920 Reduced

General-duty citation text

29 CFR 1910.1200(h)(3)(ii): Employee training did not include the physical and health hazards of the chemicals in the work area:   a) The employer does not ensure that employees are trained in the physical and health hazards of the chemicals in the work area.  This violation occurred when employees were not trained on the fire and explosion hazards of transferring and handling flammable liquids.