OSHA Inspection: OMG AMERICAS, INC.

Issued

Aug 29, 2014

Abate by

Sep 25, 2014

Penalty

Initial $2,625 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i): The Process Hazard Analysis did not address the hazards of the process    a) OMG Americas, Inc. / 240 Two Mile Run Road, Franklin, PA: the 2007 PHA for TBB/680C (subsystems) did not include an analysis of what would occur with the highly hazardous chemical (HHC) if there was a utility loss in the facility. Utility loss may include, but is not limited to, loss of electric, water, steam, air, etc.    b) OMG Americas, Inc. / 240 Two Mile Run Road, Franklin, PA: the 2007 PHA for TBB/680C (subsystems) did not include an analysis of what would occur with the HHC if there was a loss of ventilation for building 24.

Issued

Aug 29, 2014

Abate by

Sep 25, 2014

Penalty

Initial $2,625 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(vii): The process hazard analysis did not address a qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace.    A.)OMG Americas, Inc. / 240 Two Mile Run Road, Franklin, PA: the 2007 PHA for TBB/680C (subsystems) did not include a qualitative evaluation of the possible safety and health effects of failure of controls on employees in the workplace for equipment, including, but not limited to, IDAT, IDAT pumps/pump discharge manifold, IDAT condenser/reflux tank, IDAT scrubber tank, IDAT distillation column, CO Dehydrator condenser, Hot oil cooler/oil drain tank, Butanol PU storage tanks, TBB storage tank, 680C intermediate storage tank and Tank 68. The PHA only included "What if" questions followed by recommendations.

Issued

Aug 29, 2014

Abate by

Sep 25, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not address the consequences of the failure of engineering and administrative controls.  a) OMG Americas, Inc. / 240 Two Mile Run Road, Franklin, PA: the 2007 PHA for TBB/680C (subsystems) did not include deviations and/or failures of engineering and administrative controls. Potential failures of engineering controls could include, but were not limited to, horizontal piping/lines which do not drain completely for maintenance work. Failures of administrative controls could include, but were not limited to, improper positioning of valves within the system.

Issued

Aug 29, 2014

Abate by

Oct 17, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not address human factors:   a) OMG Americas, Inc. / 240 Two Mile Run Road, Franklin, PA: the 2007 Process Hazard Analysis for the TBB/680C (subsystems) did not include an evaluation of potential human factor error situations.  Potential examples of human factors not evaluated include, but are not limited to, manual computer entry/data entry errors, manually opening or closing incorrect valves, ability of employees to respond to system alarms, potential errors related to manually moving and connecting hoses, and methods of shift changeover/turnover communication regarding system status.

Issued

Aug 29, 2014

Abate by

Sep 25, 2014

Penalty

Initial $2,625 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(7):  The employer did not retain the process hazard analysis (PHA), updates, or renewals for each process covered and documented resolution of the recommendations described in 29 CFR 1910.119(e)(5) for the life of the process.    A.)OMG Americas, Inc.  - On or about March 4, 2014, the company was unable to locate documentation of the process hazard analysis and updates or revalidation for TBB/680C, conducted after the initial analysis in 2007.

Issued

Aug 29, 2014

Abate by

Oct 31, 2014

Penalty

Initial $2,625 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iv): The documentation of each inspection and test that was performed on the process did not identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test:     a.) OMG Americas, Inc.  - On or about March 4, 2014, and at times prior thereto, inspection, testing, and preventive maintenance records did not contain information as required.  Examples of missing information included, but were not limited to, R15 rupture disk, TF 1/1A Tank Flame Arrest & Vent and IDAT Pressure Relief Vent inspections did not include the results of the inspection or test performed.