OSHA Inspection: BASF

Issued

Nov 4, 2013

Abate by

Dec 7, 2013

Penalty

Initial $4,250 · Current $2,975 Reduced

General-duty citation text

OSH ACT of 1970 Section (5)(a)(1): Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to the hazard of fire and explosion;  At the time of the inspection, employees were not required to use non-sparking tools in areas where Phosphorus Pentasulfide(P2S5) was handled. In the Thimet/Counter process employees had access to metal sparking tools where P2S5 was stored, transferred, and unloaded. Employees were not trained to use non-sparking tools for opening containers or cleaning up spills of P2S5.   One method of abatement to correct this apparent hazard is to comply with NIOSH International Chemical Safety Cards ICSC: 1407 lists explosion prevention by using non-sparking tools.  DISCLAIMER:  a)  The employer is not limited to the abatement method suggested by OSHA b)  The employer is responsible for selecting and implementing an effective abatement method.   Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citations.

Issued

Nov 4, 2013

Penalty

Initial $3,400 · Current $2,380 Reduced

General-duty citation text

29 CFR 1910.23(c)(1): Open-sided floors or platforms 4 feet (1.22 m) or more above the adjacent floor or ground level were not guarded by standard railings (or the equivalent as specified in 29 CFR 1910.23(e)(3)(i) through (v)), on all open sides:  At the time of the inspection, the following open sided floors were not guarded with a standard railing that included a midrail  1. Three openings on east and three on west side of Pyrrole building. 2. Platform to access rail car unload station.  Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citations.

Issued

Nov 4, 2013

Abate by

Dec 7, 2013

Penalty

Initial $4,250 · Current $2,975 Reduced

General-duty citation text

29 CFR 1910.119(f)(4): 29 CFR 1910.119(f)(4):  The employer did not develop or implement safe work practices for employees and contractors performing high risk maintenance activities on covered processes.  At the time of the inspection, the employer had not developed and implemented adequate safe work practices for the installation and replacement of temporary pipe repairs in covered processes.   Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citations.

Issued

Nov 4, 2013

Abate by

Dec 7, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not implement written procedures to maintain the on-going integrity of process equipment.  At the time of the inspection, the employer had not developed and implemented an adequate procedure for installing and replacing temporary pipe repairs on covered processes.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citations.

Issued

Nov 4, 2013

Abate by

Dec 7, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(3): The employer did not train employees involved in maintaining the on-going integrity of process equipment in an overview of the inspection process and the procedures required to perform the employee's job tasks.  At the time of the inspection, BASF and contractor employees had not been adequately trained on procedures to install and replace temporary pipe clamps and repairs.   Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citations.

Issued

Nov 4, 2013

Abate by

Dec 7, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(h)(2)(iv): The employer did not develop and implement safe work practices consistent with paragraph (f)(4) of this section to control the entrance, presence and exit of contract employers and contract employees in the covered process areas.  At the time of the inspection, contract employees such ad KBR had not been trained in adequate procedures to install and replace temporary pipe clamps and repairs.   Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citations.

Issued

Nov 4, 2013

Abate by

Nov 22, 2013

Penalty

Initial $4,250 · Current $2,975 Reduced

General-duty citation text

29 CFR 1910.119(j)(6)(iii): The employer shall assure that maintenance materials, spare parts and equipment are suitable for the process application for which they will be used.  At the time of the inspection, temporary pipe repairs in the Prowl plant were made on the EDC line with pipe clamp containing neoprene gasket that was not compatible with the process.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citations.

Issued

Nov 4, 2013

Abate by

Dec 7, 2013

Penalty

Initial $4,250 · Current $2,975 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer shall establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.  At the time of the inspection, the employer had not developed and implemented management of change for the installation of temporary ppe repairs on the following leaking pipes; a) The Ethylene Di-Chloride line in Prowl. b) The Ethanol condensor line in Thimet/Counter. c) The Aqueous waste in Thimet/Counter.  Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citations.

Issued

Nov 4, 2013

Abate by

Dec 7, 2013

Penalty

Initial $4,250 · Current $2,975 Reduced

General-duty citation text

29 CFR 1910.119(m)(5): The employer shall establish a system to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions shall be documented.  At the time of the inspection, the following temporary pipe repairs had not been promptly addressed by completing permanent reapirs;  a) An EDC(Ethylene Di-Chloride) leak was contained with a temporary patch then a temporary pipe clamp on or about 6/28/2013 and as of 9/18/13 had not been replaced with permanent piping.   b) The Ethanol condensor line in Thimet/Counter was patched with hose clamps and gasket. On 12/15/2012 the patch was found to be leaking. As of 9/18/2013 the pipe had not been repaired.   Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citations.

Issued

Nov 4, 2013

Abate by

Dec 23, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(m)(1): The employer shall investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace.  At the time of the inspection, there was no incident report available for a leak that was found and repaired on the EDC(Ethylene Di-Chloride) line in the Prowl process.