OSHA Inspection: CHEMICAL & METAL INDUSTRIES INC

Issued

2014-02-28 00:00:00

Abate by

2014-04-04 00:00:00

Penalty

Initial $1360.00 · Current $680.00 Reduced

General-duty citation text

29 CFR 1910.101(b): The in-plant handling, storage, and utilization of all compressed gases in cylinders, portable tanks, rail tankcars or motor vehicle cargo tanks was not in accordance with Compressed Gas Association Pamphlet P-1-1965:    (a) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc did not ensure that the in-plant handling, storage, and utilization of all compressed gases in cylinders, portable tanks, rail tankcars or motor vehicle cargo tanks was in accordance with Compressed Gas Association Pamphlet P-1-1965.  Employees transported ton containers of chlorine using a Hyster model S65XM powered industrial truck within the facility.  Ton containers of chlorine were moved while laying horizontally across the fork blades of the powered industrial truck.  The ton containers of chlorine were not firmly secured during transportation.  The employer did not ensure that the transportation of the ton containers of chlorine was in accordance with CGA Pamphlet P-1, Section 3.2.6.  This condition exposed employees to a chemical hazard.

Issued

2014-02-28 00:00:00

Abate by

2014-05-05 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.178(o)(1): Load(s) on powered industrial truck(s) were not stable or safely arranged:      (a) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc did not ensure that loads on powered industrial trucks were stable or safely arranged.  Employees transported ton containers of antimony trichloride or antimony pentachloride using a Hyster model S65XM powered industrial truck within the facility.  The ton containers were moved while laying horizontally across the fork blades of the powered industrial truck.  The ton containers were not firmly secured during transportation.  The employer did not ensure that the ton containers were stable or safely arranged.  This condition exposed employees to a chemical hazard.

Issued

2014-02-28 00:00:00

Abate by

2014-05-04 00:00:00

Penalty

Initial $1360.00 · Current $680.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's compiled written process safety information did not include all the necessary information pertaining to the equipment in the process in that the process safety information did not include all affected equipment in the piping and instrument diagram (P&ID's):    (a) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc's compiled written process safety information did not include all the necessary information pertaining to the equipment in the process in that the process safety information did not include all affected equipment in the piping and instrument diagram (P&ID's).  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  A vent pipeline traveled from the filter pot to knockout pot KO-201.  The vent pipeline was missing from the P & ID for KO-201.  The P & ID was not updated correctly to show the filter pot vent pipeline to KO-201.  This condition exposed employees to a chemical hazard.     (b) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/16/13, Chemical & Metal Industries Inc's compiled written process safety information did not include all the necessary information pertaining to the equipment in the process in that the process safety information did not include all affected equipment in the piping and instrument diagram (P&ID's).  The employer used chlorine to produce antimony pentachloride. The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  A vent pipeline traveled from the low arsenic packaging station to knockout pot KO-201.  The vent pipeline was missing from the P & ID for KO-201.  The P & ID was not updated correctly to show the low arsenic packaging station vent pipeline to KO-201.  This condition exposed employees to a chemical hazard.       (c) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/16/13, Chemical & Metal Industries Inc's compiled written process safety information did not include all the necessary information pertaining to the equipment in the process in that the process safety information did not include all affected equipment in the piping and instrument diagram (P&ID's).  The employer used chlorine to produce antimony pentachloride. The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  A vent pipeline traveled from knockout pot KO-201 to scrubber SC-991.  A ball valve downstream from rupture disk PSE2153 was present on the P & ID, but was not present on the unit.  The P & ID was not updated correctly to show that the ball valve was not present.  This condition exposed employees to a chemical hazard.

Issued

2014-02-28 00:00:00

Abate by

2014-06-04 00:00:00

Penalty

Initial $0.00 · Current $0.00

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) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc did not document that equipment complies with recognized and generally accepted good engineering practices.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  The facility's RX-201 process unit was constructed in 2002.  Welded process piping, which had been constructed in 1998 at their previous location, was utilized in the construction of the unit.  Chemical & Metal Industries Inc did not document that the welding procedure used was qualified for the piping system per the RAGAGEP, American Society of Mechanical Engineers (ASME) B31.3 "Process Piping".  This condition exposed employees to a chemical hazard.     (b) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc did not document that equipment complies with recognized and generally accepted good engineering practices.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  The facility's RX-201 process unit was constructed in 2002.  Welded process piping, which had been constructed in 1998 at their previous location, was utilized in the construction of the unit.  Chemical & Metal Industries Inc did not document that the welders peforming the work were qualified for the welding procedure per the RAGAGEP, American Society of Mechanical Engineers (ASME) B31.3 "Process Piping".  This condition exposed employees to a chemical hazard.     (c) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc did not document that equipment complies with recognized and generally accepted good engineering practices.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  The facility's RX-201 process unit was constructed in 2002.  Welded process piping, which had been constructed in 1998 at their previous location, was utilized in the construction of the unit.  Chemical & Metal Industries Inc did not document that the welds were inspected per the RAGAGEP's, American Society of Mechanical Engineers (ASME) B31.3 "Process Piping".  This condition exposed employees to a chemical hazard.

Issued

2014-02-28 00:00:00

Abate by

2014-05-04 00:00:00

Penalty

Initial $1360.00 · Current $680.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(iv):  The employer's Process Hazard Analysis (PHA) did not address consequences of failure of engineering and administrative controls:    (a) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc's Process Hazard Analysis did not address consequences of failure of engineering and administrative controls.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  The employer updated and revalidated its PHA for reactor RX-103 in 2012.  The PHA did not address consequences of failure of engineering controls, including but not limited to pressure relief valves or rupture disks.  This condition exposed employees to a chemical hazard.    (b) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc's Process Hazard Analysis did not address consequences of failure of engineering and administrative controls.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  The employer updated and revalidated its PHA for chlorine vaporizer VC-101 in 2012.  The PHA did not address consequences of failure of engineering controls, including but not limited to pressure relief valves or rupture disks.  This condition exposed employees to a chemical hazard.

Issued

2014-02-28 00:00:00

Abate by

2014-05-04 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(e)(3)(v): The employer's Process Hazard Analysis did not address facility siting:  (a) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc's Process Hazard Analysis did not facility siting.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  The employer updated and revalidated its PHA for reactor RX-103 in 2012.  The PHA did not address facility siting, including but not limited to impact of a chlorine release upon the office building.  This condition exposed employees to a chemical hazard.  (b) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc's Process Hazard Analysis did not address facility siting.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  The employer updated and revalidated its PHA for chlorine vaporizer VC-101 in 2012.  The PHA did not address facility siting, including but not limited to impact of a chlorine release upon the office building.  This condition exposed employees to a chemical hazard.

Issued

2014-02-28 00:00:00

Abate by

2014-05-04 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The employer's Process Hazard Analysis did not address human factors:  (a) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc's Process Hazard Analysis did not human factors.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  The employer updated and revalidated its PHA for reactor RX-103 in 2012.  The PHA did not address human factors, including but not limited to impact of inadequate training or color blindness.  This condition exposed employees to a chemical hazard.  (b) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc's Process Hazard Analysis did not address human factors.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  The employer updated and revalidated its PHA for chlorine vaporizer VC-101 in 2012.  The PHA did not address human factors, including but not limited to impact of inadequate training or color blindness.  This condition exposed employees to a chemical hazard.

Issued

2014-02-28 00:00:00

Abate by

2014-05-04 00:00:00

Penalty

Initial $1360.00 · Current $680.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(6): The employer did not ensure that the Process Hazard Analysis was updated and revalidated by a team meeting the requirements in paragraph (e)(4) of this section at least every five (5) years after the completion of the initial Process Hazard Analysis:    (a) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc did not ensure that the Process Hazard Analysis was updated and revalidated by a team meeting the requirements in paragraph (e)(4) of this section at least every five (5) years after the completion of the initial Process Hazard Analysis.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  The employer developed a Process Hazard Analysis for reactor RX-201 in 2002, when the unit was constructed.  The employer did not ensure that a PHA for RX-201 was updated and revalidated at least every five years since 2002.  This condition exposed employees to a chemical hazard.    (b) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc did not ensure that the Process Hazard Analysis was updated and revalidated by a team meeting the requirements in paragraph (e)(4) of this section at least every five (5) years after the completion of the initial Process Hazard Analysis.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  The employer developed a Process Hazard Analysis for chlorine vaporizer VC-201 in 2002, when the unit was constructed.  The employer did not ensure that a PHA for VC-201 was updated and revalidated at least every five years since 2002.  This condition exposed employees to a chemical hazard.

Issued

2014-02-28 00:00:00

Abate by

2014-05-04 00:00:00

Penalty

Initial $1360.00 · Current $680.00 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:    (a) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc did not establish and implement written procedures to maintain the on-going integrity of process equipment.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  Employees performed inspections of process equipment including but not limited to, piping systems, scrubbers, and rupture disks.  The employer did not establish and implement written procedures to follow when performing mechanical integrity inspections or testing of process equipment.  This condition exposed employees to a chemical hazard.

Issued

2014-02-28 00:00:00

Abate by

2014-05-04 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(j)(3): The employer did not train each employee involved in maintaining the on-going integrity of process equipment in the procedures applicable to the employee's job tasks:   (a) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc did not train each employee involved in maintaining the on-going integrity of process equipment in the procedures applicable to the employee's job tasks.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  Employees performed inspections of process equipment including but not limited to, piping systems, scrubbers, and rupture disks.  The employer did not train the employees in the procedures to follow when performing mechanical integrity inspections or testing of process equipment.  This condition exposed employees to a chemical hazard.

Issued

2014-02-28 00:00:00

Abate by

2014-05-04 00:00:00

Penalty

Initial $1360.00 · Current $680.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The employer's frequency of inspections and tests of process equipment was not consistent with applicable manufacturer's recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience:    (a) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/16/13, Chemical & Metal Industries Inc's frequency of inspections and tests of process equipment was not consistent with applicable manufacturer's recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.   Employees performed inspections of pressure vessels, piping systems, controls, relief systems, and other process equipment.  Chlorine vaporizer VC-201 contained a pressure vessel protected by rupture disk PSE2056 and pressure relief valve PSV2057.  Pressure relief valve PSV2057 was not inspected or tested on a regularly scheduled basis.  The employer did not ensure that inspection and testing of the pressure relief valve followed RAGAGEP as written in The Chlorine Institute Pamphlet 9 "Chlorine Vaporizing Systems".  This condition exposed employees to a chemical hazard.    (b) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/16/13, Chemical & Metal Industries Inc's frequency of inspections and tests of process equipment was not consistent with applicable manufacturer's recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.   Employees performed inspections of pressure vessels, piping systems, controls, relief systems, and other process equipment.  Chlorine vaporizer VC-201 contained a pressure vessel that utilized a steam jacket.  The steam supply piping contained pressure relief valve PSV2063.  Pressure relief valve PSV2063 was not inspected or tested on a regularly scheduled basis.  The employer did not ensure that inspection and testing of the pressure relief valve followed RAGAGEP as written in The Chlorine Institute Pamphlet 9 "Chlorine Vaporizing Systems".  This condition exposed employees to a chemical hazard.    (c) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/16/13, Chemical & Metal Industries Inc's frequency of inspections and tests of process equipment was not consistent with applicable manufacturer's recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.   Employees performed inspections of pressure vessels, piping systems, controls, relief systems, and other process equipment.  Reactor RX-201 was cooled using a heat transfer fluid system.  The piping for the heat transfer fluid contained pressure relief valve PSV2009.  Pressure relief valve PSV2009 was not inspected or tested on a regularly scheduled basis.  The employer did not ensure that inspection and testing of the pressure relief valve followed RAGAGEP as written in American Petroleum Institute API RP 576 "Inspection of Pressure-relieving Devices".  This condition exposed employees to a chemical hazard.

Issued

2014-02-28 00:00:00

Abate by

2014-04-04 00:00:00

Penalty

Initial $1360.00 · Current $680.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(6)(iii): The employer did not assure that maintenance materials, spare parts, and equipment were suitable for the process application for which they will be used:    (a) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc did not assure that maintenance materials, spare parts, and equipment were suitable for the process application for which they will be used.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  A process involving chlorine took place within reactor RX-201.  The U-1 for reactor RX-201 indicated that the Maximum Allowable Working Pressure was 100 psi.  The P & ID for reactor RX-201 specified that the rupture disk for PSE-2007 was to be rated for 100 psi.  The replacement rupture disk for reactor RX-201 was rated for 107 psi.  The employer did not ensure that the rupture disk for reactor RX-201 was suitable for the process application.  This condition exposed employees to a chemical hazard.

Issued

2014-02-28 00:00:00

Abate by

2014-08-04 00:00:00

Penalty

Initial $1360.00 · Current $680.00 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not certify that they had evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard were adequate and were being followed:    (a) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/10/13, Chemical & Metal Industries Inc did not certify that they had evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard were adequate and were being followed.  The employer used chlorine to produce antimony pentachloride.  The total inventory of chlorine utilized and stored within the facility was 8,000 pounds.  An audit of the process safety management program was last done in 2007.  The employer did not certify that they had evaluated compliance with the provisions of the process safety management standard at least every three years since 2007.  This condition exposed employees to a chemical hazard.

Issued

2014-02-28 00:00:00

Abate by

2014-04-04 00:00:00

Penalty

Initial $1360.00 · Current $680.00 Reduced

General-duty citation text

29 CFR 1910.147(c)(2)(ii): The employer's energy control program under paragraph (c)(1) of this section did not utilize lockout, where the energy isolating device was capable of being locked out:    (a) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/16/13, Chemical & Metal Industries Inc did not ensure that the energy control program under paragraph (c)(1) of this section utilized lockout, where the energy isolating device was capable of being locked out.  Employees utilized energy control procedures on equipment including but not limited to when employees performed thickness testing upon chlorine vaporizer VC-201.  VC-201 and its affiliated equipment, including but not limited to the steam supply and return, have multiple energy sources, including electrical, chemical, and thermal.  The employer's energy control plan utilized tags when closing valves to isolate an energy source.  The valves were capable of utilizing lockout.  The employer did not ensure that lockout was used when closing valves to isolate an energy source.  This condition exposed employees to an uncontrolled hazardous energy source.

Issued

2014-02-28 00:00:00

Abate by

2014-04-04 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.147(c)(4)(ii)(B):  The energy control procedures did not clearly and specifically outline the steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy:  (a) Chemical & Metal Industries Inc, at 23465 Chem-Tech Avenue, Hudson, CO: On and preceding 12/16/13, Chemical & Metal Industries Inc did not ensure that the energy control procedures clearly and specifically outlined the steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy.  Employees utilized energy control procedures on equipment including but not limited to when employees performed thickness testing upon chlorine vaporizer VC-201.  VC-201 and its affiliated equipment, including but not limited to the steam supply and return, have multiple energy sources, including electrical, chemical, and thermal.  The employer's energy control procedure for VC-201 did not contain specific procedures for the de-energization and control of the hazardous energy sources.  This condition exposed employees to uncontrolled hazardous energy sources.