OSHA Inspection: GATX RAIL CORPORATION

Issued

Jan 15, 2015

Abate by

Mar 5, 2015

Penalty

Initial $4,400 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not assure that PHA recommendations were resolved in a timely manner.     On or about 27 August 2014, and at times prior thereto, the employer did not ensure that open action items from the May 2009 Hazard and Operability (HAZOP) study were completed. The new HAZOP had a listing of recommendations, but did not have for each recommended item the responsible parties assigned, an expected due date, the frequency of review of the listing for updates, or the person responsible for maintaining the listing. As a result, two items remained open from the May 2009 HAZOP.  Instance 1: Open action item R2.6.1, fully loaded cars can present a derailment or spill hazard during switching, with the action of placing signs on cars to warn that it is fully loaded, exposing the employees involved with the system to the hazard of being caught in or struck by a rail car due to derailment, in addition to a fire or explosion hazard from the resulting spill.

Issued

Jan 15, 2015

Abate by

Mar 5, 2015

Penalty

Initial $4,400 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(3): The employer did not annually certify that operating procedures were current and accurate.    On or about 27 August 2014, and at times prior thereto, the employer did not review as often as necessary and certify on an annual basis the operating procedures for the flare system and car cleaning to ensure they were current and accurate, exposing the employees performing the tasks to the hazard of being struck by flying debris or objects as a result of an explosion effect, or to various fire hazards.

Issued

Jan 15, 2015

Abate by

Mar 5, 2015

Penalty

Initial $5,500 · Current $5,340 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(ii): 29 CFR 1910.119(j)(4)(ii): Inspections and testing procedures performed on process equipment to maintain its mechanical integrity did not follow recognized and generally accepted good engineering practices (RAGAGEP).    On or about 27 August 2014, and at times prior thereto, the employer did not implement a mechanical integrity program for process equipment that included inspection and testing procedures for the flare and purging systems, exposing the employees to the hazard of being struck by flying debris or objects from an explosion, or various fire hazards. During the purging process, flammable gas and liquid residue is evacuated from the pressurized tank cars at the Purge Rack, up to 10 tank cars possible at a time, and burned off to atmosphere at the flare. These purge lines are near the flare and run along the Purge Rack that has electrical lines for lighting purposes. A leak in any of the lines would increase the likelihood of a flash fire explosion from either the flare or electrical exposure.

Issued

Jan 15, 2015

Abate by

Jan 22, 2015

Penalty

Initial $3,300 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.145(c)(2)(i): Caution signs were not used to warn against potential hazards or to caution against unsafe practices.     On or about 27 August 2014, and at times prior thereto, two storage sheds did not have placards indicating the nature of the materials being stored within, such as Sulfuric Acid and Caustic Soda Flakes, exposing employees nearby or entering the buildings to either inhalation, corrosive or fire hazards. In the event of firefighting at the Purge Rack adjacent to the two sheds due to a fire or explosion effect, both the Sulfuric Acid and Caustic Flakes are highly corrosive with water acting as a catalyst causing an extremely volatile reaction when added.

Issued

Jan 15, 2015

Abate by

May 5, 2015

Penalty

Initial $1,100 · Current $500 Reduced

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.    On or about 27 August 2014, and at times prior thereto, the employer did not possess the design basis for the flare used in the purging system, exposing employees working in the area to the hazard of being struck by flying objects from an explosion or fire hazards.

Issued

Jan 15, 2015

Abate by

May 5, 2015

Penalty

Initial $1,100 · Current $500 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F): Information pertaining to the equipment in the process did not include design codes and standards that were employed.    On or about 27 August 2014, and at times prior thereto, the employer did not have the design codes and standards for the waste gas disposal system utilized for the purging process of the tank cars, exposing the employees to the hazard of being struck by flying objects from an explosion or fire hazards.

Issued

Jan 15, 2015

Abate by

Mar 5, 2015

Penalty

Initial $1,100 · Current $500 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 have been corrected.    On or about 27 August 2014, and at times prior thereto, the employer did not effectively follow up on findings or deficiencies noted within the RMP Compliance Audits conducted in June 2012 and April 2014, exposing employees who work with the waste gas disposal system to the hazard of being struck by flying objects or burns due to an explosion and/or fire.  Instance 1: The 2012 Audit & Certification Form was generated as a result of the RMP Compliance Audit in that year. The form's column for Compliance Met is completely blank for all 20 listed items.  Instance 2: The 2014 RMP Compliance Audit indicated four findings and recommendations which did not have any completion dates, due dates, estimated completion dates, or party responsible because the employer did not have a tracking mechanism in place.