OSHA Inspection: BECK ALUMINUM ALLOYS, LTD.

Issued

Aug 7, 2014

Abate by

Sep 3, 2014

Penalty

Initial $6,930 · Current $1,500 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(c)(3): The employer did not provide employees and their representatives access to process hazard analyses and to all other information required to be developed under this standard:     (a) The employer did not assure that workers were provided access to the process hazard analyses.  For example, worker(s) who participated in the 2013 Annual Safety Audit were not provided access to the process hazard analyses, to use in the audit.

Issued

Aug 7, 2014

Abate by

Sep 3, 2014

Penalty

Initial $4,950 · Current $2,970 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(d)(2)(i)(C): Process safety information pertaining to the technology of the process did not include the maximum intended quantity:       (a)    The employer's maximum intended inventory of chlorine listed in "Chlorine Operation - General Work Instructions" (I7.5.1A dated 7/1/2011) was 8 or less full [1-ton] cylinders.  However, the employer disclosed a "Maximum Amount" of 20,000 lbs. chlorine, as listed in Beck Aluminum's 1/29/2014 document: "Racine County EPCRA Hazardous Materials Response Plan - Off-Facility Plan."  Thus, incorrect information was presented by the employer with regard to the maximum intended inventory of chlorine.

Issued

Aug 7, 2014

Abate by

Feb 3, 2015

Penalty

Initial $6,930 · Current $4,100 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(d)(2)(i)(D): Safe upper and lower limits for such items as temperature, pressures, flows or compositions pertaining to the technology of the process were not compiled before conducting any process safety analysis required by this standard:     (a) Chlorine Room and the Production area: Chlorine piping and manifold system, associated with the covered process, did not have the safe upper and lower limits for the pressure identified in the Process Safety Information compiled by the employer.  The omission of this process safety information potentially increased the risk of an over-pressure event, exposing workers to chlorine vapor which could have corrosive effects on eyes and respiratory tract.

Issued

Aug 7, 2014

Abate by

Feb 3, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): The employer did not include, in the process safety information compilation, the relief system design and the design basis:      (a) No relief system was installed to protect chlorine piping from overpressure.  According to the Chlorine Institute (Pamphlet 6, Edition 16, 2013, p. 5), piping in which liquid chlorine can be trapped between closed valves must be protected.  The employer's process safety information compilation, as listed on p. 4 of I7.5.1A "Chlorine Operation - General Work Instructions"  erroneously indicated that the Chlorine Institute does not recommend a chlorine relief system.  This condition potentially exposed workers to corrosive chlorine liquid and gas.

Issued

Aug 7, 2014

Abate by

Feb 3, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 0640

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) No relief system was installed to protect chlorine piping from overpressure.  According to the Chlorine Institute (Pamphlet 6, Edition 16, 2013, p. 5), piping in which liquid chlorine can be trapped between closed valves must be protected, considering liquid chlorine's high coefficient of thermal expansion which could cause piping rupture when temperature increases occur.  The employer's process safety information compilation, as listed ion p. 4 of I7.5.1A "Chlorine Operation - General Work Instructions"  erroneously indicated that the Chlorine Institute does not recommend a chlorine relief system.  This condition potentially exposed workers to corrosive chlorine liquid and gas.

Issued

Aug 7, 2014

Abate by

Sep 3, 2014

Penalty

Initial $6,930 · Current $4,100 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer did not include and identify all equipment that was part of the process on piping and instrument diagrams:     (a) The "Beck Aluminum Chlorine System Flow Diagram" did not include and identify the type of yoke valve by which the flex hose connected to the 1-ton Chlorine cylinder.     (b) Aside from the two Needle valves which were identified, the "Beck Aluminum Chlorine System Flow Diagram" did not identify the type(s) of valves associated with the piping system.     (c) The "Beck Aluminum Chlorine System Flow Diagram" did not include and identify an emergency shut off valve that was located between the two Needle valves, in the vicinity of Furnace #5.     (d) The "Beck Aluminum Chlorine System Flow Diagram" included gauges, but did not identify the type(s) of gauges.     (e) The "Beck Aluminum Chlorine System Flow Diagram" included two flex hoses (one to chlorine cylinder, the other to pump in Furnace #5), but it did not identify the type(s) of flex hoses.     (f) The "Beck Aluminum Chlorine System Flow Diagram" did not include and identify the fitting located on the left end of the pipe run in the Chlorine Room at which nitrogen may be connected to the piping system.     (g) The "Beck Aluminum Chlorine System Flow Diagram" did not include and identify the cap fitting located on the right end of the pipe run in the Chlorine Room.

Issued

Aug 7, 2014

Abate by

Sep 16, 2014

Penalty

Initial $4,950 · Current $4,950

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(e)(3)(i): The Process Hazard Analysis did not address the hazards of the process:     (a) The 2010 Process Hazard Analysis (PHA) did not address the fire hazard that could occur in relation to the chlorine process.  The chlorine process involved conveyance of pressurized chlorine from one-ton cylinders in the Chlorine Room, through a flex hose and piping to Furnace #5 in the Production Area where the chlorine was delivered via a flex hose and pump into the molten metal for the purpose of reducing the magnesium content of the aluminum alloy.  None of the PHA items addressed the potential hazard of a foundry fire.  A fire in the foundry could expose workers in the area to burn hazards and chlorine exposure, in the event of hose and/or pipe rupture.  A fire in the foundry could also result in increasing temperatures in the Chlorine Room, which potentially could result in melting of soft plugs in one-ton chlorine cylinder(s) and release of hazardous concentrations of chlorine vapors into the Chlorine Room and adjacent areas.

Issued

Aug 7, 2014

Abate by

Sep 16, 2014

Penalty

Initial $4,950 · Current $0 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(e)(3)(ii): The process hazard analysis did not address the identification of any previous incident which has a likely potential for catastrophic consequences in the workplace:     (a) The employer's Process Hazard Analysis, dated June, 2010, did not address an incident that occurred in 1989 in which a soft plug in a 1-ton chlorine cylinder blew out, releasing the contents of the cylinder and resulting in a plant-wide evacuation.

Issued

Aug 7, 2014

Abate by

Sep 16, 2014

Penalty

Initial $6,930 · Current $0 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not address the consequences of failure of engineering and administrative controls:     (a) The Process Hazard Analysis/Fault Mode Effect Analysis (PHA/FMEA) which the employer had performed in June, 2010, did not address the consequences of failure of engineering and administrative controls.   For example, the PHA/FMEA did not address the impact of a power failure and the consequences of failure of the emergency back-up power supply.  A power outage could result in unsafe lighting conditions for workers performing work on the chlorine system, which could contribute to errors in performing chlorine related operations, potentially resulting in release of chlorine vapor, and could also impair safe emergency egress in event of an uncontrolled chlorine vapor release. Power failure would also result in loss of exhaust venting for the furnace, potentially resulting in accumulation of smoke in the plant, that in addition to poor lighting conditions could impair safe emergency egress from the plant.   It was not evaluated whether loss of pump operation could affect pressure in the chlorine piping.

Issued

Aug 7, 2014

Abate by

Sep 16, 2014

Penalty

Initial $6,930 · Current $4,100 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the team's findings and recommendations; assure that the recommendations were resolved in a timely manner and that the resolution was documented; document what actions were to be taken; complete actions as soon as possible; develop a written schedule of when these actions were to be completed; communicate the actions to operating, maintenance and other employees whose work assignments were in the process and who may have been affected by the recommendations or actions:    (a) The employer's June, 2010 process hazard analysis (PHA) of chlorine operational steps did not adequately address the control of hazards involved in the process.  The PHA followed Failure  Mode Effect Analysis (FMEA) to evaluate the potential failure modes, potential effects of failure, current process controls, and recommended actions.  According to the PHA/FMEA procedure, each PHA/FMEA item was assigned a Risk Priority Number (RPN) and any RPN identified greater than 50 was to be addressed for improvement and the schedule of actions were to be documented.   Under the heading "Disconnect System", the operational step identified as "Remove yoke from cylinder" was assigned a RPN of 54.   The recommended actions listed for this PHA/FEMA were "Tighten back up & drain line", but aside from these  measures, this PHA/FEMA did not adequately address how to improve this operational step, and no schedule of actions to achieve such improvement was documented.

Issued

Aug 7, 2014

Abate by

Sep 3, 2014

Penalty

Initial $6,930 · Current $0 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(B): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information which addressed precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment:        (a) The Chlorine Handling Team operating procedure included in slide #84 "Chlorine Alarm Settings" provided explanation regarding the low limit set point of 1 PPM (parts per million) and the high limit set point of 10 PPM.  According to the instructions on this slide, the Chlorine Handling Team members can respond for "15 minutes maximum with 3M 6800 full face shield respirator".   However, this instruction did not take into account that a chlorine concentration of 10 PPM  is IDLH (Immediately Dangerous to Life and Health) and the 3M 6800 full face shield respirator is not approved for use at or above 10 PPM.

Issued

Aug 7, 2014

Abate by

Nov 3, 2014

Penalty

Initial $6,930 · Current $4,100 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(j)(4)(ii): The inspection and testing procedures did not follow recognized and generally accepted good engineering practices:       (a) The employer's program for inspection and testing of chlorine piping in the Chlorine Room and the Production area were not in accordance with the guidelines listed by The Chlorine Institute (e.g., Pamphlet 6 and Pamphlet 85), in that it did not include tests to periodically assess at regular intervals pipe wall thickness.  Non-destructive testing was not done, for example by means of ultrasonic thickness measurements, to evaluate corrosion rates and fitness for service (measured pipe wall thickness was not compared to minimum wall thickness to determine fitness for service).

Issued

Aug 7, 2014

Abate by

Sep 16, 2014

Penalty

Initial $4,950 · Current $2,970 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not implement procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process:         No management of change procedures were followed prior to making changes to the covered process.  This  placed workers at increased risk for exposure to corrosive chlorine liquid and gas.       a.  A change was made regarding the Maximum Intended Inventory of chlorine used and stored in the Chlorine Room.  According to I7.5.1A "Chlorine Operation - General Work Instructions" (dated 7/01/2011), the Maximum Intended Inventory of full chlorine (1-ton) cylinders was 8 or less cylinders (which equated to 16,000 lbs.).  On 1/29/2014 the employer issued "Racine County EPCRA Hazardous Materials Response Plan - Off-Site Facility Plan", which listed the Maximum Amount of chlorine as 20,000 lbs. (which equated to 10 cylinders).       b. On or around January 6, 2014. the employer arranged for an outside contractor to disconnect pipe supplying liquid chlorine to Furnace #3.  In the Chlorine Room, the valve for Furnace #3 was shut off, locked out, a section of pipe was removed after the valve, and a cap installed downstream of the valve.  In the Production area, a section of the manifold pipe supplying chlorine to Furnace #3 was removed and capped.

Issued

Aug 7, 2014

Abate by

Sep 16, 2014

Penalty

Initial $6,930 · Current $4,100 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not evaluate compliance with the provisions of this section to verify that the procedures and practices developed under the standard were adequate and being followed:     (a) The annual safety audit, which was performed to review compliance with process safety procedures, did not include an adequate review of the Process Safety Information compilation to determine whether it continued to be accurate or was in need of correction or update.  For example, the "Chlorine Operation - General Work Instruction", which was dated 03/11/2011 included the statement that the Chlorine Institute (with reference to Pamphlet 6 "Piping Systems for Dry Chlorine") does not recommend a chlorine relief system.  However, the March, 2013 edition of Pamphlet 6 recommended that care must be taken to protect piping from overpressure where chlorine (particularly if in the liquid state, considering its thermal expansion properties) may be trapped between closed valves.  However, the 2013 safety audit (performed on August 8, 2013) did not review the current Chlorine Institute publication and correct the Process Safety Information regarding relief system design and design basis.     (b)  The annual safety audits did not include review of Process Hazard Analysis to determine if recommended actions and target completion dates had been identified.      (c) The annual safety audits did not include review of Management of Change Procedures (MOC) to evaluate whether MOC procedures were being appropriately followed in the event that changes were made to the chlorine process.     (d) The annual safety audits did not include review of the written training program for chlorine procedures.  There was not an evaluation of the adequacy of training content and frequency.  Nor was there evaluation of how well the training was communicated to the affected workers.

Issued

Aug 7, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.23(a)(8): Every floor hole into which persons could accidentally walk was not guarded by either a standard railing with standard toeboard on all exposed sides, or a floor hole cover of standard strength and construction.  While the cover was not in place, the floor hole was not constantly attended by someone or protected by a removable standard railing:   (a) In the Production Area, in the vicinity of the #1 Control Room for the circulating pump and adjacent to the aisle way, there was gap or floor hole between two steel plates, which exposed workers to a potential trip hazard.