OSHA Inspection: A. HYATT BALL CO LTD

Issued

Apr 1, 2015

Abate by

Jun 30, 2017

Penalty

Initial $2,800 · Current $7,000

General-duty citation text

OSH ACT of 1970 Section (5)(a)(1): Respondent (a) did not ground the ductwork for the Pangborn dust collection system to prevent any static electricity generated by the movement of phenol-formaldehyde resin dust over the metal ducts from becoming a potential ignition source; (b) did not ground the Pangborn dust collector itself to prevent the generation of static electricity from becoming a potential ignition source; (c) did not control sparks generated by the metal chucks of the lathe from striking the metal clamps that secured the phenol-formaldehyde resin balls during shaping, which could travel into the Pangborn dust collection system and ignite the dust; (d) ductwork for the Pangborn dust collection system had 90 degree angle bends where phenol-formaldehyde dust could accumulate and potentially ignite; (e) supported the ducting next to the dust collector with bricks loosely stacked, resulting in breaks in the ductwork, leading to the potential release of phenol-formaldehyde resin dust; and (f) did not provide explosion relief venting for the Pangborn dust collection system to prevent a fire in the collector from traveling back into the building through the duct work.

Issued

Apr 1, 2015

Abate by

Jun 6, 2016

Penalty

Initial $2,000 · Current $7,000

General-duty citation text

29 CFR 1910.106(h)(4)(i)(d): Three (55) gallon drums of a 37% solution of formaldehyde, a Class 4 flammable liquid were stored on the first floor in a room that did not meet the requirements for an inside storage room as outlined in 1910.106(d)(4)(I).

Issued

Apr 1, 2015

Abate by

Sep 6, 2016

Penalty

Initial $2,800 · Current $5,000

General-duty citation text

29 CFR 1910.106(h)(6)(ii)(d): The processing area on the second floor of the building above the kettles being used to manufacture phenol-formaldehyde resins (where the formaldehyde being used to make the resin was a 37% solution classified as a Class 4 flammable liquid) was not equipped with an approved automatic sprinkler system or equivalent system.

Issued

Apr 1, 2015

Abate by

Jul 6, 2016

Penalty

Initial $2,800 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.106(h)(6)(iii): An alarm system to notify workers in the plant and for contacting the local fire department had not been established and is required due to the use of 37% formaldehyde, a Class 4 flammable liquid in 55 gallon drums at the facility.  A procedure for notifying the workers and the local fire department will be developed in the emergency action plan and all employees will receive training on the procedures in the emergency action plan.

Issued

Apr 1, 2015

Abate by

Apr 6, 2016

Penalty

Initial $2,000 · Current $5,000

General-duty citation text

29 CFR 1910.106(h)(7)(i)(a): The metal suction fill pipe used to draw formaldehyde under vacuum from a  plastic 55 gallon drum into kettle #3 was not grounded during transfer to prevent static electricity from being generated.

Issued

Apr 1, 2015

Abate by

Jun 6, 2016

Penalty

Initial $2,800 · Current $7,000

General-duty citation text

29 CFR 1910.119(c)(1): Respondent did not develop a written plan of action for employee participation in process safety management.

Issued

Apr 1, 2015

Abate by

Jun 6, 2016

Penalty

Initial $2,800 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i): Process safety information pertaining to the technology of the process did not include the elements specified in 29 CFR 1910.119(d)(2)(i)(A) through (E):    (a) On or about October 3, 2014, at the facility, the employer failed to compile process safety information pertaining to the technology of the process used to manufacture phenol-formaldehyde resins including but not limited to:        1) A block flow diagram or simplified process flow diagram      2) Maximum intended inventory for formaldehyde      3) Safe upper and lower limits for operating under vacuum pressure for kettle #3      4) Safe upper and lower limits for operating under vacuum pressure and temperature for kettle #4       5) An evaluation of the consequences of deviations, including those affecting the safety and health of employees

Issued

Apr 1, 2015

Abate by

Jun 6, 2016

Penalty

Initial $2,800 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i): Process safety information pertaining to the equipment in the process did not include the elements specified in 29 CFR 1910.119(d)(3)(i)(A) through (H):    (a) On or about October 3, 2014, at the facility, the employer failed to compile process safety information pertaining to the technology of the process used to manufacture phenol-formaldehyde resins including but not limited to:        1) Materials of construction for kettles #3 and#4      2) Materials of construction for the packing material installed on the primary vacuum pump        2) Piping and instrument diagrams      3) Electrical classification      4) Design codes and standards employed

Issued

Apr 1, 2015

Abate by

Jun 6, 2016

Penalty

Initial $2,800 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complied with recognized and generally accepted good engineering practices:      a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The faceplate identifying the manufacturer, the vessel, and design specifications was missing. The faceplate is required to be present on the vessel as required under such as, but not limited to API 620-2008, "Design and Construction of Large, Welded, Low-Pressure Storage Tanks, section 1.1.        (b) On or about October 3, 2014, at the facility, kettle #3 and kettle #4 was designed and built as a pressure vessel by the manufacturer. They were modified after manufacturing and hydrostatic testing to operate under vacuum pressure in this production process. The employer did not subject the vessels to pressure and vacuum testing after this alteration as required under such as, but not limited to API 572-2009, "Inspection Practices for Pressure Vessels," section 9.7.2.    (c) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting resin into custom sized balls. The steam and vacuum piping including valves throughout the processing equipment were not labeled as to their identity and the direction of flow using the requirements outlined in such as, but not limited to ASME A13.1-2007, "Scheme for the Identification of Piping Systems".        (d) On or about October 3, at this facility, for employees manufacturing phenol-formaldehyde resins and casting resin into custom sized balls. Kettles #3 and #4 were not equipped with safe valves to relieve pressure, if over pressurization occurred in these low pressure reactors during this exothermic reaction.  The requirement to install pressure-relieving valves and emergency vacuum-reliving valves is covered under the requirements outlined in such as, but not limited to API Standard 620-2008, " Design and Construction of Large, Welded, Low Pressure Storage Tanks," section

Issued

Apr 1, 2015

Abate by

Jun 6, 2016

Penalty

Initial $2,800 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(1): The employer did not perform an initial process hazard analysis (hazard evaluation) on processes covered by 29 CFR 1910.119:      a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The employer had not performed an initial process hazard analysis for the storage of the formaldehyde and the process of manufacturing the phenol-formaldehyde resins. The employer is covered under 1910.119 because more than 1,000 lbs of formaldehyde were observed in storage on the first floor of the building on October 3, 2014.

Issued

Apr 1, 2015

Abate by

Jun 6, 2016

Penalty

Initial $2,800 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(1): 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 and which addressed elements listed in 29 CFR 1910.119(f)(1)(i) through (f)(1)(v):     (a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls.  The employer did not develop and implement operating procedures for operating phases including initial startup, temporary operations, normal operations for kettle #4, emergency shutdown, emergency operations, normal shutdown, and startup following a turnaround, or after an emergency shutdown.

Issued

Apr 1, 2015

Abate by

Jun 6, 2016

Penalty

Initial $2,800 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(4): The employer did not develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel:    (a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The employer had not developed and implemented safe work practices to provide for the control of lockout hazards encountered while employees perform servicing and maintenance on process equipment and opened process equipment to replace valves. The employer is covered under 1910.119 because more than 1,000 lbs of formaldehyde were observed in storage on the first floor of the building on October 3, 2014.

Issued

Apr 1, 2015

Abate by

Jun 6, 2016

Penalty

Initial $2,800 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(i)(1): The employer did not perform a pre-startup safety review for new facilities and for modified facilities when the modification was significant enough to require a change in the process safety information:    (a)  On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The employer did not perform a pre-startup safety review after the Kinney portable backup vacuum pump was connected to the process. The employer is covered under 1910.119 because they store more than the threshold quantity of 1,000 lbs of formaldehyde on site.

Issued

Apr 1, 2015

Abate by

Jun 6, 2016

Penalty

Initial $2,800 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment:    a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The employer had not established written procedures to maintain the on-going integrity of process equipment used to manufacture the resin such as the two pressure vessels, the steam, water and vacuum piping including the valves, the relief system on the Weil Mclain boiler, the emergency shutdown switches for the boiler, the manual steam gauges located on the boiler and in the processing area and the two Kinney vacuum pumps. The employer is covered under 1910.119 because more than 1,000 lbs of formaldehyde were observed in storage on the first floor of the building on October 3, 2014.

Issued

Apr 1, 2015

Abate by

Jun 6, 2016

Penalty

Initial $2,800 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(3):The employer did not train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee could perform the job tasks in a safe manner:    a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The employer had not conducted training for employees involved in maintaining the on-going integrity of process equipment used to manufacture the resin such as the two pressure vessels, the steam, water and vacuum piping including the valves, the relief system on the Weil Mclain boiler, the emergency shutdown switches for the boiler, the manual steam gauges located on the boiler and in the processing area and the two Kinney vacuum pumps. The employer is covered under 1910.119 because more than 1,000 lbs of formaldehyde were observed in storage on the first floor of the building on October 3, 2014.

Issued

Apr 1, 2015

Abate by

Jun 6, 2016

Penalty

Initial $2,800 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:    (a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The employer did not develop and implement an inspection plan for the two pressure vessels as outlined in documents such as but not limited to API 572-2009, " Inspection Practices for Pressure Vessels", section 6.       (b)  On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins and casting the resin into custom sized balls. The Weil-McLain low-pressure steam boiler, Boiler EG/PEG-50,  was not inspected either  internally or externally as required by New York State Industrial Code Rule 4. This steam boiler is used to supply steam to the two reactors that are manufacturing the phenol-formaldehyde resins.

Issued

Apr 1, 2015

Abate by

Jun 6, 2016

Penalty

Initial $2,800 · Current $0 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) On or about October 3, 2014, in the processing area, for the gate valve on kettle #4 used to control steam that was replaced with a Tasco Flocontrol Valve, a combination valve and flow control instrument. The employer did not establish written procedures to manage this change in equipment and procedures.

Issued

Apr 1, 2015

Abate by

Jun 6, 2016

Penalty

Initial $2,800 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(n): The employer did not establish an emergency plan for the entire plant in accordance with the provisions of 29 CFR 1910.38:     (a) On or about October 3, 2014, at the facility, for employees manufacturing phenol-formaldehyde resins for casting into custom sized resin balls. The employer did not establish an emergency action plan to address the procedures to follow in the event of a fire and responding to small and large spills of chemicals. The facility handles and stores formaldehyde and phenol in 55 gallon drums.  There were 1,118 lbs. of formaldehyde on the site on October 3, 2014. The threshold quantity for formaldehyde requiring coverage under 1910.119 is 1,000 lbs.    (b) On or about December 2014, at the facility, for an employee using a fork lift truck to bring a 55 gallon drum of 2-propoxyethanol ordered by Plastic Maritime Corporation, a separate company that leases space from this employer, into their shared storage space on the first floor.  The employer did not establish an emergency action plan to address the procedures to follow in the event of a spill of these chemicals during transport.

Issued

Apr 1, 2015

Abate by

May 6, 2016

Penalty

Initial $2,800 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.132(a): Protective equipment was not used by an employee when a hose was used to put out a fire in the outside dust collector.