OSHA Inspection: ULTRATEC SPECIAL EFFECTS, INC.

Issued

Aug 4, 2015

Abate by

Aug 28, 2015

Penalty

Initial $5,390 · Current $3,542 Reduced

General-duty citation text

29 CFR 1910.36(d)(1): Employee(s) were not able to open an exit route door from the inside at all times without keys, tools, or special knowledge:    (a) On or about 2/16/15 - at B3 Shipping building, the west side exit door was locked and required a key to unlock it.  The exit door was not equipped with panic type hardware.

Issued

Aug 4, 2015

Abate by

Aug 10, 2015

Penalty

Initial $5,390 · Current $4,312 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(C): Process safety information pertaining to the equipment in the process did not include the electrical classification:    (a) On or about 2/6/15 - at Maintenance building in garage area, the employer did not correctly evaluate and classify an area that was used to manufacture and press pyrotechnic compounds such as Angel Fire gerbs.

Issued

Aug 4, 2015

Abate by

Aug 10, 2015

Penalty

Initial $5,390 · Current $0 Reduced

General-duty citation text

29 CFR 1910.307(c)(2)(i): Equipment in hazardous (classified) location(s) was not approved for the ignitable or combustible properties of the specific gas, vapor, dust, or fiber that was or could be present:    (a) On or about 2/6/15 - Maintenance building garage area, unapproved equipment such as the fluorescent light fixtures, household ceiling fan and light fixture, bench grinder motor, and drill press motor were used in the same area where employees manufactured a pyrotechnic composition using the Angel Fire Gerb press.  The garage area was incorrectly identified as an unclassified area when it should be minimally classified as "Class II, Division 2".

Issued

Aug 4, 2015

Abate by

Sep 4, 2015

Penalty

Initial $5,390 · Current $4,312 Reduced

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) On or about 2/6/15 - at West side processing buildings, the employer did not provide exhaust ventilation design information showing that ventilation was adequate for composition mixtures where flammable liquids such as but not limited to toluene were used to in pyrotechnic compositions such as Angel Fire Comets Red Tracer Comp that was manufactured in building A10.

Issued

Aug 4, 2015

Abate by

Aug 10, 2015

Penalty

Initial $5,390 · Current $5,390

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) On or about 2/6/15 - at A10 processing building, the employer failed to document and ensure compliance with recognized and generally accepted good engineering practices to protect employees exposed to explosion and fire hazards based on the safety standards the company relied on to comply with the standard.  Employees were engaged in the manual mixing and blending of pyrotechnic compositions.     (b) On or about 2/6/15 - at A10 processing building, the employer failed to document and ensure compliance with recognized and generally accepted good engineering practices to protect employees exposed to explosion and fire hazards when manually screening and grinding pyrotechnic compositions based on the safety standards the company relied on to comply with this standard.     (c) On or about 2/6/15 - at A10 processing building, the employer failed to document and ensure compliance with recognized and generally accepted good engineering practices to protect employees exposed to explosion and fire hazards as specified in the National Fire Protection Association (NFPA) 1124-2006 Code for the Manufacture, Transportation, Storage, and Retail Sales of Fireworks and Pyrotechnic Articles section 4.5.2.2 in that a metal table was present with nonconductive material on top in an area where pyrotechnic material was being mixed.  Please note:  The employer will need to identify in the PSM process safety documentation the proper identification of the type of composition and whether or not the NFPA definition for "salute powder" applies to the processes being conducted at the facility.    (d) On or about 2/6/15 - at A10 processing building, the employer failed to document and ensure compliance with recognized and generally accepted good engineering practices to protect employees exposed to explosion and fire hazards in that employees were using metal screens with a wooden frame.  The wooden frame could not be grounded.

Issued

Aug 4, 2015

Abate by

Aug 14, 2015

Penalty

Initial $5,390 · Current $5,390

General-duty citation text

29 CFR 1910.119(e)(3)(iii): The process hazard analysis did not address engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies:  (a) On or about 2/6/15 - At West Processing Buildings, the process hazard analysis did not address the engineering or administrative controls, procedures, or methods to ensure that the maximum limit of 500-lbs. of pyrotechnics and/or explosive compositions and a maximum weight of 10-lbs. of salute powder in loose form or in assembled units was not exceeded during processing and staging pyrotechnic compositions in multiple buildings such as A2 and A4 to A12.

Issued

Aug 4, 2015

Abate by

Aug 21, 2015

Penalty

Initial $5,390 · Current $4,312 Reduced

General-duty citation text

29 CFR 1910.119(e)(6): The employer did not update and revalidate by a team meeting the requirements in paragraph (e)(4) of this section, to assure that the process hazard analysis is consistent with the current process, at least every five (5) years after the completion of the initial process hazard analysis:    (a) On or about 2/6/15 - at West Side, the process hazard analysis for a PSM covered pyrotechnic process used to manufacture Starmines was not updated and revalidated at least every five (5) years.  Since the initial process hazard analysis was validated on 10/06/09, the process has been changed to use the new Hobart mixer.    (b) On or about 2/6/15 - at West Side, the process hazard analysis for a PSM covered pyrotechnic process used to manufacture Angel Fire Comets was not updated and revalidated at least every five (5) years.  Since the initial process hazard analysis was validated on 10/07/09, the employer had a fire incident 10/2/14 that involved Angel Fire Tracer Comet processing.

Issued

Aug 4, 2015

Abate by

Aug 14, 2015

Penalty

Initial $5,390 · Current $5,390

General-duty citation text

29 CFR 1910.119(f)(1)(i): 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 steps for each operating phase:    (a) On or about 2/6/15 - at East Side Building C6 Big Press, the procedure used to manufacture the pyrotechnic composition "Waterfall 20 SEC Gold" did not define the calculation required to determine the amount of composition to be added for the second composition press or the third step.    (b) On or about 2/6/15 - at A6 processing building, employees were allowed to stand outside the doorway of pyrotechnic process building A6 where a mechanical mixer was used to stir explosive compositions.

Issued

Aug 4, 2015

Abate by

Aug 28, 2015

Penalty

Initial $5,390 · Current $5,390

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:    (a) On or about 2/6/15 - at West Side A6 building, management of change was not implemented for the PSM covered pyrotechnic process of "Preparing Ammonium Perchlorate based Starmines" when the process was changed from hand mixing to using a Hobart mixer.    (b) On or about 2/6/15 - at West Side A11 building, management of change was not implemented for the PSM covered process of Star Priming when the Star roller was rebuilt after the 10/2/14 fire and a pneumatic tilt was added.    (c) On or about 2/6/15 - at Maintenance building, management of change was not implemented for the PSM covered process of Pressing Angel Fire Gerbs when the process was changed to use the new Angel Fire Gerb Press.    (d) On or about 2/6/15 - at A10 processing building, Red Tracer Comp was identified as being appropriate for processing in building A7, A4, A5, A6.  However, a change was made to the Red Tracer Comp SOP which identified "All process building" as appropriate for mixing Red Tracer Comp using the safety standards relied on by the employer to comply with the standard.

Issued

Aug 4, 2015

Abate by

Dec 1, 2015

Penalty

Initial $5,390 · Current $4,312 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not certify that they have evaluated compliance with the provisions of this section at least every three years:    (a) On or about 2/6/15  - at 148 Moon Drive, Owens Cross Road, AL, an evaluation had not been conducted at least every three years to ensure compliance with the Process Safety Management regulations.

Issued

Aug 4, 2015

Abate by

Dec 1, 2015

Penalty

Initial $5,390 · Current $4,312 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 had been corrected:    (a) On or about 2/6/15  - at 148 Moon Drive, Owens Cross Road, AL, the employer did not document an appropriate response to each of the findings and that the deficiencies had been corrected as identified in the APT Research, Inc. Safety Assessment conducted in September 2009.  Recommendations, such as but not limited to, "7. Use expanding foam to fill in holes and gaps in the walls of all processing and mixing buildings, to include those around air ducts." and "14. For operations that are determined to be more sensitive or hazardous than the norm or that require the use of material that is highly reactive to static electricity, implement the use of wrist straps."

Issued

Aug 4, 2015

Abate by

Aug 10, 2015

Penalty

Initial $3,080 · Current $2,464 Reduced

General-duty citation text

29 CFR 1910.303(b)(2): Listed or labeled electrical equipment was not used or installed in accordance with instructions included in the listing or labeling:    (a) On or about 2/6/15 -  at East Side C2 building, a relocatable power strip was not used in accordance with instructions to power two heat lamps and an automatic air bleeder water valve.

Issued

Aug 4, 2015

Abate by

Oct 10, 2015

Penalty

Initial $3,851 · Current $3,851

General-duty citation text

29 CFR 1910.1200(f)(6)(ii): Except as provided in 29 CFR 1910.1200(f)(7) and 29 CFR 1910.1200(f)(8), the employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals and which, in conjunction with the other information immediately available to employees under the hazard communication program, would provide employees with the specific information regarding the physical and health hazards of the hazardous chemical:    (a) On or about 2/6/15 - at the East Side C6 Large Press Room, a metal container identified as HF4 was not labeled, tagged, or marked to identify the hazard of explosion.    (b) On or about 2/6/15 - at the East Side C6 Large Press Room, a cardboard container containing pyrotechnic composition of X20 Sliver LMH or Safety Demo was not labeled, tagged, or marked to identify the hazard of explosion.

Issued

Aug 4, 2015

Abate by

Oct 10, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(f)(6)(i): Except as provided in 29 CFR 1910.1200(f)(7) and 29 CFR 1910.1200(f)(8), the employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the information required by 29 CFR 1910.1200(f)(1)(i) through 29 CFR 1910.1200(f)(1)(v):    (a) On or about 2/6/15 - at the East Side C6 Large Press Room, a cardboard container containing pyrotechnic composition was labeled as X20 Sliver LMH on the side and as Safety Demo on the top.

Issued

Aug 4, 2015

Abate by

Oct 10, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(h)(3)(iv):   The details of the hazard communication program developed by the employer, did not include an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information and how employee could obtain and use the appropriate hazard information:    (a) On or about 2/6/15 - at 148 Moon Drive, Owens Cross Roads, AL, the employer had not provided training to all potentially exposed employees on the Hazard Communication Standard (HCS 2012) new label elements (e.g., pictograms and signal words) and the new SDS format (i.e., the section order and the type of information contained within each section) by the 12/1/2013 required date.