OSHA Inspection: BAZE CHEMICAL, INC.

Issued

Aug 31, 2015

Abate by

Sep 3, 2015

Penalty

Initial $4,900 · Current $2,205 Reduced

General-duty citation text

29 CFR 1910.37(a)(3): The exit access lead into a dead-end corridor:      a) The signs posted in the control room (building 7), along the exit access, lead employees to a dead-end.

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $4,900 · Current $2,205 Reduced

Hazardous substances 1190

General-duty citation text

29 CFR 1910.119(c)(1):  The employer did not develop a written plan of action regarding the implementation of the employee participation required by 29 CFR 1910.119:    a) On or about March 17, 2015, and at times thereafter, the employer did not ensure that a written plan of action regarding implementation of the employee participation was developed in the event of an ethylene oxide release.

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $4,900 · Current $2,205 Reduced

Hazardous substances 1190

General-duty citation text

119(d)(2)(i)(A) Information concerning the technology of the process did not include a block flow diagram or simplified process flow diagram:      a) On or about March 17, 2015, and at times thereafter, the employer did not ensure that the information concerning the technology of the process included a block flow diagram or simplified process flow diagram in the event of an ethylene oxide release.

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $4,900 · Current $2,205 Reduced

Hazardous substances 1190

General-duty citation text

119(d)(2)(i)(C)  Information concerning the technology of the process did not include the maximum intended inventory:    a) On or about March 17, 2015, and at times thereafter, the employer did not develop or implement process safety information to include the maximum intended inventory of a highly hazardous chemical  in the event of an ethylene oxide release.

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $4,900 · Current $2,205 Reduced

Hazardous substances 1190

General-duty citation text

29 CFR 1910.119(d)(2)(i)(D):  The information concerning the technology of the process did not include the safe upper and lower limits for temperatures, pressures, flows or compositions:    a) The employer did not ensure that process safety information included the safe upper and lower limits for temperatures and pressures in the event of an ethylene oxide release.

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $4,900 · Current $2,205 Reduced

Hazardous substances 1190

General-duty citation text

119(d)(3)(i)(C):  Information concerning the technology of the process did not include the Electrical Classification:      (a) On or about March 17, 2015, and at times thereafter, the employer's process safety information did not include electrical classification for equipment used in the processing of ethylene oxide.

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $4,900 · Current $2,205 Reduced

Hazardous substances 1190

General-duty citation text

1910.119(d)(3)(i)(H): Process safety information pertaining to the equipment in the process did not include safety systems (e.g. interlocks, detection or suppression system):      On or about March 17, 2015, and at times thereafter, the employer did not document the process safety information for equipment safety systems such as, but are not limited to the following:      a) Ethylene Oxide sensors  b) Deluge system  c) Flare  d) EM-100   e) LAHH-100  f) PAHH-100  g)TAHH-100  h) EM-101  i) LAHH-101  j) PAHH-101  k)TAHH-101

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $4,900 · Current $2,205 Reduced

Hazardous substances 1190

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 employed:    On or about March 17, 2015, and at times thereafter, the employer exposed employees to inhalation, fire, and explosion hazards when it did not include design codes and standards employed in the information pertaining to the ethylene oxide process equipment.  Design codes and standards include, but are not limited to NFPA 15 (Standard for Water Spray Fixed Systems for Fire Protection), NEC (National Electrical Code), API 537 (Flare Details for General Refinery and Petrochem Service), ANSI (American National Standards Institute), ASME (American Society of Mechanical Engineers) Boiler & Pressure Vessel Code.  The equipment includes but are not limited to:      a) Ethylene Oxide Storage Tank, T-100 (P&ID: PID-100-01, date 10/15/13)    b) Ethylene Oxide Storage Tank, T-101(P&ID: PID-T-101-01, date 05/07/13)    c) Reactor Tank, R-100 (P&ID: PID-R-100, date 01/15/14)    d) Reactor Tank, R-200 (P&ID: PID-R-200, date 06/05/14)    e) SS-2-SC.40 (from an EO railcar through the pump P-101 to Storage Tanks, T-100 and T-101 listed on the P&ID: PRO, T-100-02 date 11/16/14)    f) SS-4-SC.40 (from Storage Tanks, T-100 and T-101 through the pump P-100 to Reactor R-100 and Reactor R200 listed on the  P&IDs: PRO, T-100-02 date 11/16/14, PID-R-100, date 01/15/14 and PID-R-200, date 06/05/14)    g) Flare system    h) Deluge system/sprinkler

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $7,000 · Current $3,150 Reduced

Hazardous substances 1190

General-duty citation text

119(e)(1): The employer did not perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard.  The process hazard analysis was not appropriate to the complexity of the process and did not identify, evaluate, and control the hazards involved in the process.  Employers shall determine and document the priority order for conducing process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process:      a) On or about March 17, 2015, and at times thereafter, the employer did not conduct a process hazard analysis for the evaluation and control of the hazards involved in the process, exposing employees to inhalation, fire, and explosion hazards.

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $7,000 · Current $3,150 Reduced

Hazardous substances 1190

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 addressing at least steps for each operating phase, safe operating limits, safety and health considerations, and safety systems and their functions as outlined by this paragraph:    On or about March 17, 2015, and at times thereafter, the employer does not ensure that written operating procedures for ethylene oxide processes were developed and implemented, exposing employees to inhalation, fire, and explosion hazards. The written operating procedures must include, but not be limited to the following elements:    a) Steps for each operating phase including Initial startup.    b) Steps for each operating phase including Normal operations.    c) Steps for each operating phase including Temporary operations.    d) Steps for each operating phase including Emergency shutdown and including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner.    e) Steps for each operating phase including Emergency Operations.    f) Steps for each operating phase including Normal shutdown.    g) Steps for each operating phase including Startup following a turnaround, or after an emergency shutdown.    h) Operating limits.    i) Consequences of deviation.    j) Steps required to correct or avoid deviation.    k) Safety and health considerations including Properties of, and hazards presented by, the chemicals used in the process.    l) Safety and health considerations including Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment.    m) Safety and health considerations including Control measures to be taken if physical contact or airborne exposure occurs.    n) Safety and health considerations including Quality control for raw materials and control of hazardous chemical inventory levels.    o) Safety and health considerations including Any special or unique hazards.    p) Safety systems and their functions.

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $7,000 · Current $3,150 Reduced

Hazardous substances 1190

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 entrance into a facility by maintenance, contractor, laboratory, or other support personnel:       (a) The employer did not ensure that safe work practices were developed and implemented for the control over entrance into the ethylene oxide process area by maintenance, contractor and other support personnel.

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $4,900 · Current $2,205 Reduced

Hazardous substances 1190

General-duty citation text

29 CFR 1910.119(g)(1)(i): Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, was not trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training should include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks:    a) On or about March 17, 2015, and at times thereafter, the employer did not ensure that each employee involved in the processing of ethylene oxide was trained in the operating procedures as specified in paragraph (f).

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $4,900 · Current $2,205 Reduced

Hazardous substances 1190

General-duty citation text

29 CFR 1910.119(h)(2)(i):  The employer, when selecting a contractor, did not obtain and evaluate information regarding the contract employer's safety performance and programs.      On or about March 17, 2015, and at times thereafter, the employer did not obtain and evaluate the contract employers' safety performance and programs. Contractors selected and who had performed tasks in the facility, included but were not limited to:      (a) Mark Henderson Electric, Inc.    (b) Coherent Technologies, Inc.    (c) Greg Industrial Insulators

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $7,000 · Current $3,150 Reduced

Hazardous substances 1190

General-duty citation text

29 CFR 1910.119(i)(1):  The employer did not perform a pre-startup safety review for new facilities:      a) On or about March 17, 2015, and at times thereafter, the employer did not ensure that a pre-startup safety review was completed with regard to potential releases of ethylene oxides that were used in a batch manufacturing process.

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $7,000 · Current $3,150 Reduced

Hazardous substances 1190

General-duty citation text

29 CFR 1910.119(j)(2):  The employer did not establish and implement written procedures to maintain the on-going mechanical integrity of process equipment:      On or about March 17, 2015, and at times thereafter, the employer did not establish and implement written procedures for the on-going mechanical integrity for process equipment which include, but are not limited to:      a) Ethylene Oxide storage T-100    b) Ethylene Oxide storage T-101    c) Ethylene Oxide storage T-102    d) Reactor R-100    e) Reactor R-200    f) SV-100A    g) SV-100B    h) SV-101a    i)  SV-101    j)  Valve GL-104    k) Valve GL-101-5    l) Pump P-100    m) Pump P-101

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $7,000 · Current $3,150 Reduced

Hazardous substances 1190

General-duty citation text

29 CFR 1910.119(j)(4)(iv): The employer did not document each inspection and test that has been performed on process equipment:    On or about March 17, 2015, and at times thereafter, the employer exposed employees did not document hydrostatic testing performed on process equipment.  There was no documentation maintained to identify the date of the test, the name of person performing test, serial number or other identifier of the equipment tested, description of test performed, and results of test.  Equipment includes but is not limited to the following:      a) Ethylene Oxide Storage Tank, T-100 (P&ID: PID-100-01, date 10/15/13).    b) Ethylene Oxide Storage Tank, T-101(P&ID: PID-T-101-01, date 05/07/13)R-100.    c) Reactor Tank, R-100 (P&ID: PID-R-100, date 01/15/14).    d) Reactor Tank, R-200 (P&ID: PID-R-200, date 06/05/14).    e) Deluge System.    f)  Ethylene Oxide Sensors.    g) GL-104 on P&ID: PID-100-01 (date10/15/13).    h) GL-101-5 on P&ID: PID-T-101-01 (date 5/07/13).    i)  P-100 on P&ID: PROC. T-100-01 (date 11/16/14).    j).  P-101 on P&ID: PROC. T-100-01 (date 11/16/14).    k). EM-100 on the P&ID (PID-100-01 date 10/15/13).    l)  LAHH-100 on the P&ID (PID-100-01 date 10/15/13).    m) TAHH- 100 on the P&ID (PID-100-01 date 10/15/13).    n) PAHH-100 on the P&ID (PID-100-01 date 10/15/13).    o) EM-101 on the PI&D (PID-T-101-01 date 5/07/13).    p) LAHH-101 on the P&ID (PID-T-101-01 date 5/07/13).    q) PAHH-101 on the P&ID (PID-T-101-01 date 5/07/13).    r) TAHH-101 on the P&ID (PID-T-101-01 date 5/07/13).    s) SS-2-SC.40 (from an EO railcar through the pump P-101 to Storage Tanks, T-100 and T-101 listed on the P&ID: PRO, T-100-02 date 11/16/14).    t) SS-4-SC.40 (from Storage Tanks, T-100 and T-101 through the pump P-100 to Reactor R-100 and Reactor R200 listed on the  P&IDs: PRO, T-100-02 date 11/16/14, PID-R-100, date 01/15/14 and PID-R-200, date 06/05/14).

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $7,000 · Current $3,150 Reduced

Hazardous substances 1190

General-duty citation text

29 CFR 1910.119(k)(1) The employer did not issue a hot work permit for hot work operations conducted on or near a covered process:      a) On or about March 31, 2015, hot work permits were not issued when employees performed welding operations in the facility where ethylene oxide was present.

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $7,000 · Current $3,150 Reduced

Hazardous substances 1190

General-duty citation text

29 CFR 1910.119(n) The employer did not establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38:    On or about March 17, 2015, and at times thereafter, the employer did not to establish and implement an emergency action plan to ensure that each employee working at the facility was protected from emergencies involving ethylene oxide.  The emergency action plan must include, but is not limited to the following:    a) Procedures for reporting a fire or other emergency.    b) Procedures for emergency evacuation, including type of evacuation and exit route assignments.    c) Procedures to be followed by employees who remain to operate critical plant operations before they evacuate.    d) Procedures to account for all employees after evacuation.    e) Procedures to be followed by employees performing rescue or medical duties.    f) The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan.    g) Employee alarm system with a distinctive signal for each purpose.     h) Employee training.    i) Review of emergency action plan with each employee covered by the plan.    j) Procedures for handling small releases.

Issued

Aug 31, 2015

Abate by

Sep 22, 2015

Penalty

Initial $4,900 · Current $2,205 Reduced

General-duty citation text

29 CFR 1910.178(l)(1)(ii): Prior to permitting an employee to operate a powered industrial truck (except for training purposes), the employer did not ensure that each operator had successfully completed the training required by 29 CFR 1910.178(l):    a) Employees operated forklift trucks without having first completed training consisting of formal instruction, practical training, and an evaluation of the operator's performance in the workplace.