OSHA Inspection: CARTRIDGE ACTUATED DEVICES, INC.

Issued

Sep 24, 2014

Abate by

Jun 19, 2015

Penalty

Initial $4,900 · Current $5,750

General-duty citation text

29 CFR 1910.119(c)(2): The employer did not consult with employees and their representatives on the conduct and development of process hazard analyses and on the development of the other elements of process safety management in this standard.    a) Production building (Building 2)     The employer did not consult with employees on the development of hazard analyses and operating procedures.  Cartridge Actuated Devices prepared explosive mixtures and substances and manufactured devices containing explosive materials including, but not limited to, silver azide and lead azide.    Violation occurred on or about 5/6/14.

Issued

Sep 24, 2014

Abate by

Jun 19, 2015

Penalty

Initial $4,900 · Current $5,750

General-duty citation text

29 CFR 1910.119(d)(3)(i)(C): Information pertaining to the equipment in the process did not include the electrical classification:    a) Production Facility - Building 2    The employer did not have a document indicating the electrical classification of areas in the production facility, where manufacture of devices using explosives took place.      Violation occurred on or about 4/3/14.

Issued

Sep 24, 2014

Abate by

Jun 19, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(E): Information pertaining to the equipment in the process did not include a ventilation system design.    a) Production Facility - Building 2    The employer's information on the ventilation system design did not include duct type and size, air flow, gate valves, design of intakes and design basis.  The local exhaust ventilation was provided for process manufacturing areas where solvents and explosive powders were used.    Violation occurred on or about 7/2/14.

Issued

Sep 24, 2014

Abate by

Jun 19, 2015

Penalty

Initial $4,900 · Current $5,750

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) The Hazard Analysis for VTDF Output Sleeve, Loaded (011094-1) did not provide a qualitative evaluation of the possible safety and health effects of explosion of HNS II, a high explosive, on assemblers at different steps in the procedure.      Violation occurred on or about 5/16/14.      b) The Hazard Analysis for Cartridge Assembly (834AS450) did not provide a qualitative evaluation of the possible safety and health effects of ignition of smokeless powder and ignition charge on assemblers at different steps in the procedure.    Violation occurred on or about 5/16/14.      c) The Hazard Analysis for Output Cup Assembly (H447414) did not provide a qualitative evaluation of the possible safety and health effects of ignition of HNS II, a high explosive,  on assemblers during weighing, inspecting and loading.    Violation occurred on or about 5/16/14.      d)  The Hazard Analysis for Internal Cup Assembly (H447412) did not provide a qualitative evaluation of the possible safety and health effects of ignition of PY-112 (silver azide, a high explosive) on assemblers during weighing, loading, inspecting,.    Violation occurred on or about 5/16/14.

Issued

Sep 24, 2014

Abate by

Jul 20, 2015

Penalty

Initial $0 · Current $0

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 that addressed health and safety considerations, such as precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment.    a) Production Facility - Building 2    The employer's written operating procedures such as, but not limited to, VTDF Output Sleeve, Loaded (011094-1) did not address the need for rubber/chemical resistant gloves, as recommended in the Safety Data Sheet, when handling HNS II powder which is harmful in contact with the skin.      Violation occurred on or about 5/16/14.      b) Production Facility - Building 2    The employer's written operating procedures such as, but not limited to CCU-126/A Cartridge Assembly (834AS450) failed to address the need for gloves when handling smokeless powder which is composed of 805 RDX (cyclonite), a chemical listed by NIOSH as hazardous through skin absorption.      Violation occurred on or about 5/16/14.

Issued

Sep 24, 2014

Abate by

Jun 19, 2015

Penalty

Initial $4,900 · Current $5,750

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) Production Facility (Building 2)    The employer did not retain documentation of the initial hazard analyses, updates or resolution of recommendations for explosive device manufacturing processes such as, but not limited to, H524167 Hi Temperature Percussion Detonator, 834AS450 CCU-126/A Cartridge Assembly and 088011-6.0 VTDF 6 Minute Delay Assembly.    Violation occurred on or about 7/24/14.

Issued

Sep 24, 2014

Abate by

Jul 20, 2015

Penalty

Initial $4,900 · Current $5,750

General-duty citation text

29 CFR 1910.119(f)(1)(i)(B): The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information:    a) The employer's written operating procedures for normal operations did not include a written procedure for preparing bays which contained workstations where explosive devices were assembled for maintenance.     Violation occurred on or about 7/21/14.      b) The employer's written operating procedures for normal operations did not include a written procedure for  emptying and cleaning waste receptacles where explosive waste was disposed.    Violation occurred on or about 7/2/14.       c) The employer did not provide clear instructions in written operating procedures for explosives preparation, loading and assembly when it failed to identify specific equipment, workstations and bays.    Violation occurred on or about 4/10/14.      d) The employer's written operating procedures for normal operations did not include a written procedure for correcting an air press that cannot meet pressure specifications when checked with a Dillon gauge..    Violation occurred on or about 8/22/14.       e) The employer's written operating procedures for normal operations did not include a written procedure for dispensing aliquots of explosive powders brought to Bay 3 Rear from storage by the Reactive Materials Engineer or Chemist.    Violation occurred on or about 8/22/14.

Issued

Sep 24, 2014

Abate by

Jul 20, 2015

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(3): The employer did not annually certify that operating procedures were current and accurate:    a) HTI Primer 072128-1 Process Operation Sheet WO 4873-02 was not certified by the employer as current and accurate since 10/25/2012.       Violation occurred on or about 7/24/14.      b)  VTDF transfer Sleeve, Loaded #011093-1 was not certified by the employer as current and accurate since 12/9/2010.       Violation occurred on or about 7/24/14.      c)  VTDF Output Initiator, Loaded #011066-1 was not certified by the employer as current and accurate since 12/9/2010.       Violation occurred on or about 7/24/14.      d)  VTDF Output Sleeve, Loaded #011094-1 was not certified by the employer as current and accurate since 12/9/2010.       Violation occurred on or about 7/24/14.      e)  Hi-Temperature Percussion Detonator, #H524167 was not certified by the employer as current and accurate since 9/20/2012.       Violation occurred on or about 7/24/14.      f)  Internal Cup Assembly H447412 was not certified by the employer as current and accurate since 9/20/2012.       Violation occurred on or about 7/24/14.      g)  Cap assembly #H447413 was not certified by the employer as current and accurate since 9/20/2012.       Violation occurred on or about 7/24/14.      h)  Output Cup Assembly #H447414 was not certified by the employer as current and accurate since 9/20/2012.       Violation occurred on or about 7/24/14.      i)  HTP Igniter #072130-1 was not certified by the employer as current and accurate since 6/29/2012.       Violation occurred on or about 8/22/14.

Issued

Sep 24, 2014

Abate by

Jul 20, 2015

Penalty

Initial $4,900 · Current $5,750

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) Production Facility - Building 2, Bay 3 Rear    The employer did not establish and implement a written procedure for maintenance of the local exhaust ventilation system used at workstations where employees handled flammable and explosive powders including HNS II and smokeless powder.     Violation occurred on or about 4/3/14.

Issued

Sep 24, 2014

Abate by

Jul 20, 2015

Penalty

Initial $4,900 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not establish and implement written procedures to manage changes  to process chemicals, technology, equipment,  and procedures; and, changes to facilities that affect a covered process.       a) Production Facility (Building 2)    The employer failed to implement management of change procedures following the installation of an articulating arm for local exhaust ventilation in Bay 3 Rear where employees handled explosive materials.    Violation occurred on or about 4/10/14.      b) Production Facility (Building 2)    The employer failed to implement management of change procedures following the installation of an articulating arm for local exhaust ventilation in Bay 2 Rear where employees conducted epoxying on explosive devices.    Violation occurred on or about 8/22/14.

Issued

Sep 24, 2014

Abate by

Jun 19, 2015

Penalty

Initial $4,900 · Current $5,500

General-duty citation text

29 CFR 1910.119(n): The employer's emergency action plan did not include procedures for handling small releases:     a) Establishment    The employer's Emergency Response Procedure failed to instruct employees on how to distinguish between small spills they can clean up themselves and large releases requiring notification and actions of others.    Violation occurred on or about 4/10/14.

Issued

Sep 24, 2014

Abate by

Jun 19, 2015

Penalty

Initial $4,900 · Current $0 Reduced

General-duty citation text

29 CFR 1910.212(a)(1): Types of guarding. One or more methods of machine guarding was not provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks. Examples of guarding methods are-barrier guards, two-hand tripping devices, electronic safety devices, etc.      a) Production facility (Building 2), Bay 7 Rear, Press station 3      Assemblers were exposed to amputation hazards while adjusting or cleaning pneumatic press 3 because the distance between control buttons in front of the press, DET #70 572, Astrosystem International Inc., was only 12 inches from center to center of the two buttons.      Violation was observed on or about 03/31/2014.

Issued

Sep 24, 2014

Abate by

Jun 19, 2015

Penalty

Initial $3,500 · Current $0 Reduced

General-duty citation text

29 CFR 1910.1025(h)(1): All surfaces were not maintained as free as practicable of accumulations of lead:    a) Production Facility (Building 2)    Weekly dry sweeping of floors did not keep them as free as practicable of lead. A wipe sample of the locker room floor on 4/9/14 had 76 micrograms of lead per square foot.  A wipe sample of Bay 3 Rear floor on 7/2/14 had 180 micrograms per square foot. of lead.  The current U.S. Dept. of Housing and Urban Development clearance level for lead on floors is 40 micrograms per square foot.    Violation occurred on or about 4/9/14.