OSHA Inspection: COIM USA INC

Issued

Aug 13, 2014

Abate by

Sep 9, 2014

Penalty

Initial $4,500 · Current $2,745 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(A): Process safety information pertaining to the equipment in the process did not include materials of construction:    a)Adhesives plant: On or about 2/19/14 the company did not have any documentation in either manual or electronic format which gave the information from the manufacturer such as but not limited to: material of construction, design pressure, temperature, maintenance, or service life for valves including but not limited to ALFA A64, A65 F; Sferova, Sferova Ball Valve- no specific model was available; Spirax/Sarco LEA 43W; and Nibco F510-CSR-66FS.    b)Adhesives plant: The Company did not have any documentation in either manual or electronic format which gave the information from the manufacturer such as but not limited to: material of construction, maintenance, or service life for pressure relieving valves including the conservation vents on or about 2/19/14.      NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 13, 2014

Abate by

Sep 9, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's information pertaining to the equipment in the process did not include piping and instrumentation diagrams (P&IDs):  a)Adhesives plant: The employer's paper P&ID did not include information pertaining to the equipment in the process in that the supply lines from storage tanks S1 (ETAC flammable liquid) and S2 (glycol) were not labeled accordingly  which had both lines listed as solvent, on or about 2/19/14.    b)Adhesives plant: The employer's electronic P&ID did not include information pertaining to the equipment in the process in that the supply lines from storage tanks S1 (ETAC flammable liquid) and S2 (glycol) were both labeled as Ethyl acetate, on or about 2/19/14.  c)Adhesive plant: The employer's paper P&ID did not include information pertaining to the equipment in the process in that the storage tank S2 (Glycol) was not labeled or indicated anywhere as to its content, on or about 2/19/14.  d) Adhesives plant: The employer's electronic P&ID did not include information pertaining to the equipment in the process in that the storage tank S2 (glycol) was labeled as ethyl acetate, on or about 2/19/14.  e)Adhesives plant: The employer's paper P&ID did not include information pertaining to the equipment in the process in that the temperature alarm high high (TAHH 1.114) and flow transmitters (FT 1.129),were only listed on the operator's electronic computer system P&ID, on or about 2/19/14.  f)Adhesives plant: The employer's paper P&ID did not include information pertaining to the equipment in the process in that the flow valve (FV1.521) was listed as a manual valve, on or about 2/19/14.  g)Adhesives plant: The employer's paper P&ID did not include information pertaining to the equipment in the process in that the symbol listed in the key for safety valves did not correlate with those listed on S1, R1, R2, and R3, on or about 2/19/14.   h) Adhesives plant: The employer's paper P&ID did not include information pertaining to the equipment in the process in that the temperature transmitters, pressure indicators and flow switch low were not labeled on S1 and reactor 1, on or about 2/19/14.  NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 13, 2014

Abate by

Sep 9, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(H): Process safety information pertaining to the equipment in the process did not include the safety systems (e.g., interlocks, detection or suppression systems):   a) Adhesives plant reactor 1 (R1): The employer did not have the process safety information pertaining to the level switch high (LSH) and level alarm high (LAH) number 1.106, including, but not limited to, the design basis, design, documents and operating parameters, on or about 2/19/14.  NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 13, 2014

Abate by

Sep 30, 2014

Penalty

Initial $4,500 · Current $2,745 Reduced

General-duty citation text

29 CFR 1910.119(e)(1): The process hazard analysis did not identify the hazards involved in the process:     a) Adhesives plant: The process hazard analysis did not identify the potential for fire from use of the vacuum system with flammable chemicals, such as, but not limited to ethyl acetate, on or about 2/19/14.    b) Adhesives plant: The process hazard analysis did not identify the potential for forklift traffic to impact the offloading  pipeline for the ethyl acetate storage tank, S1, on or about 2/19/14.       NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 13, 2014

Abate by

Sep 9, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not document the resolution of PHA recommendations:  a) Adhesives plant: On or about 2/19/14 the employer did not ensure that the recommendations from the 2008 PHA were documented. These included,  but were not limited to: -Implementation of a blow down tank inspection; -Placing the level indicator for the reactors on a preventative maintenance program to include calibration;  -Evaluate the need for a flame arrestor on the overflow tank;  -Verify the need for a manual nitrogen gauge for the inert gas used on the reactor;  -Establish a normal nitrogen reading for the inert gas used on the reactor.  b) Adhesives plant: On or about 2/19/14 the employer did not ensure that the recommendations from the 2011 PHA were documented. These included, but were not limited to: -Location of the water cannon is within the potential fire zone; -Consider remote activation of the water cannon and update any procedures based on any changes; -On the P&ID for UK01S001 add and check as necessary that  process valves fail positions; -P&ID UK01S001 and SOP AD-02 should have the same list of interlocks; add as necessary; -Update pressure safety valve and rupture disc on P&ID UK01S001 to include the information on the rating/specifications;  -Check the frequency on preventative maintenance on grounding system and consider changes if necessary.   c) Adhesives plant: On or about 2/19/14 the employer did not ensure that the recommendations from the 2013 PHA were documented. These included, but were not limited to: -Adding to the maintenance procedures statements referring to a maximum 3 month period for corrections delay without a written explanation; -Verifying that all relevant drawings have the correct number.    NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 13, 2014

Abate by

Sep 9, 2014

Penalty

Initial $4,500 · Current $2,745 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(A): Written operating procedures did not address the consequences of deviations;      a) Adhesives plant: The standard written operating procedure, AD-20 "General Manufacturing Instruction for Novacote and Imuthane Products" did not list the consequences of water or moisture being added to the batch during the manufacturing process, on or about 2/19/14.    b) Adhesives plant: The standard written operating procedure, AD-05 Cleaning Reactors using Ethyl Acetate With Drying, did not address the consequences of not completely draining ethyl acetate from the reactor after cleaning, on or about 2/19/14.       NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 13, 2014

Abate by

Sep 9, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(B): The employer's written operating procedures covering operating limits did not address the steps required to correct or avoid deviation:  a) Adhesives plant: The standard written operating procedure, AD-20 "General Manufacturing Instruction for Novacote and Imuthane Products", did not list the steps to take to avoid the addition of water or moisture to the batch during the manufacturing process, on or about 2/19/14.  b) Adhesive plant: The standard written operating procedure, AD-24 "Degassing Imuthane Batches Utilizing Vacuum", did not list the steps to take to ensure that the vacuum system is not inadvertently used with a batch containing a flammable material, on or about 2/19/14.  c) Adhesive plant: The standard written operating procedure, AD-17 "Charging Reactor Utilizing Vacuum", did not list the steps to take to ensure that the vacuum system is not inadvertently used with a batch containing a flammable material, on or about 2/19/14.     NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 13, 2014

Abate by

Sep 9, 2014

Penalty

Initial $4,500 · Current $2,745 Reduced

General-duty citation text

29 CFR 1910.119(f)(3): The employer did not certify annually that operating procedures were current and accurate.    a) Adhesives manufacturing plant: The standard written operating procedure, AD-20 "General  Manufacturing Instruction for Novacote and Imuthane Products" was not reviewed and updated since 5/11/09 to include the current practice of testing  chemicals from drums and totes and entering lot numbers from the drums and totes into the computer, on or about 2/19/14.    b) Adhesive manufacturing plant: The standard written operating procedure, AD-05 "Cleaning Reactors using Ethyl Acetate With Drying" was not reviewed and updated since 10/6/11 to include the consequences of deviation  of using the vacuum without completely drying the reactor, on or about 2/19/14.    c) Adhesive manufacturing plant: The standard written operating procedure AD-17 "Charging Reactors Utilizing Vacuum" was not reviewed and updated since 5/11/09 to include the steps the operator needs to take to verify the absence of flammable materials before using the vacuum, on or about 2/19/14.    d) Adhesive manufacturing plant: The standard written operating procedure AD-24 "Degassing Imuthane Batches Utilizing Vacuum" was not reviewed and updated  to include the steps the operator needs to take to verify the absence of flammable materials before using the vacuum, on or about 2/19/14.          NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 13, 2014

Abate by

Jun 30, 2015

Penalty

Initial $4,500 · Current $2,745 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:     a)Adhesives plant: On or about 2/19/14 inspection procedures were not developed, documented, and implemented for the pipes and associated pressure relieving devices including but not limited to the conservation vent, pressure relief valves, and blowdown tank according to RAGAGEP, such as, but not limited to, API 570 Section 4.3.1.    b)Adhesives plant: On or about 2/19/14 inspection procedures were not developed, documented, and implemented for reactors 1, 2, and 3 according to RAGAGEP, such as, but not limited to, API 510 Section 4.2.1.    NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 13, 2014

Abate by

Jun 30, 2015

Penalty

Initial $4,500 · Current $2,745 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:    a)Adhesives plant: Inspections and tests were not performed on a Pentair Varec  5400 A series flame arrestor that was installed on Storage Tank S1, on or about 2/19/14.    NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 13, 2014

Abate by

Sep 9, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment to maintain its mechanical integrity, was not consistent with applicable manufacturer's recommendations and good engineering practices, or more frequently determined to be necessary by prior operating experience.    a)Adhesives plant: Monthly oil inspections required by the manufacturer for the Renold TW Series Heavy Duty Wormgear Agitator on reactors 1,2, and 3 were not performed. Inspections were only done annually, on or about 2/19/14.  NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 13, 2014

Abate by

Sep 30, 2014

Penalty

Initial $4,500 · Current $2,745 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not establish written procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process:      a) Adhesives plant reactor two: The employer did not establish and implement management of change procedures for the temporary use of a wrench to manually open the actuated drain valve on the bottom of the reactor, on or about 3/26/14.    b Adhesives plant reactor three: The employer did not establish and implement management of change procedures for the temporary patching of the water line on reactor three, 3/26/14.    c) Adhesives plant: The employer did not establish and implement management of change procedures for the quality control steps now taken during the manufacturing process, including testing chemicals in drums and totes and entering lot numbers into the computers, on or about 3/26/14.      d) Adhesives plant: The employer did not establish and implement management of change procedures for the reduction in work force of the maintenance personnel that has resulted in delay of preventative maintenance orders from being completed, on or about 2/19/14.     NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 13, 2014

Abate by

Sep 17, 2014

Penalty

Initial $4,500 · Current $2,745 Reduced

General-duty citation text

29 CFR 1910.119(l)(4): Process safety information required by paragraph (d) of this section was not updated when a change covered by this paragraph resulted in a change in the process safety information.    a) Adhesives manufacturing plant: The employer did not update the P&IDs for reactors one and two to include removal of the spare filter housing and relocation of the circulation line, which occurred as a result of the management of change form WD13-1 generated, on or about 2/19/14.       NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Aug 13, 2014

Abate by

Sep 9, 2014

Penalty

Initial $4,500 · Current $2,745 Reduced

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 had been corrected:     a) Adhesives plant: On or about 2/19/14 the employer did not document a response for each of the findings of the 2011 compliance audit, including, but not limited to,     -Listing the consequences of deviation from operating limits and steps to correct those deviations in the SOPs.   -Generate an SOP that covered the entrance into the adhesives plant by non-essential personnel.   -Completing and implementing the  draft mechanical integrity procedure (HS-103)   -Include tasks conducted by outside contractors on such things as the heating oil system, ventilation system, fire suppression and other EHS systems associated with the adhesives plant in the inspection, testing and preventative maintenance program    - Add any special PPE and safety equipment required for use in the adhesives plant to the preventative maintenance schedule.       NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.