OSHA Inspection: THIRD COAST PACKAGING

Issued

2015-12-02 00:00:00

Abate by

2016-05-01 00:00:00

Penalty

Initial $6300.00 · Current $3300.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(1): 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:     a)  On June 9, 2015 and at times prior thereto, at the Third Coast Terminals facility in Pearland, Texas, the employer did not identify, evaluate and control the hazards that workers could be exposed as a result of FV-102 failing.     b)  On June 9, 2015 and at times prior thereto, at the Third Coast Terminals facility in Pearland, Texas, the employer did not identify, evaluate and control the hazards that workers could be exposed to as a result of TRC-102 failing.    c) On June 9, 2015 and at times prior thereto, at the Third Coast Terminals facility in Pearland, Texas, the employer did not identify, evaluate and control the hazards that workers could be exposed to as result of catastrophic failure of hoses, piping or equipment.    d) On June 9, 2015 and at times prior thereto, at the Third Coast Terminals facility in Pearland, Texas, the employer did not identify, evaluate and control the hazards that workers could be exposed to from release of process fluids, including but not limited to MEA and formaldehyde due to the inability to isolate the reactor from the scrubber.

Issued

2015-12-02 00:00:00

Abate by

2016-05-01 00:00:00

Penalty

Initial $6300.00 · Current $4500.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(4): The employer shall ensure that process hazard analysis be performed by a team with expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used.    On or about June 9, 2015, and at times thereto, at Third Coast Terminals, Pearland, TX in the MEA Triazine Unit, the employer did not ensure that the team performing the process hazard analysis included at least one employee with experience and knowledge specific to the process being evaluated.

Issued

2015-12-02 00:00:00

Abate by

2016-05-01 00:00:00

Penalty

Initial $6300.00 · Current $5700.00 Reduced

General-duty citation text

29 CFR 1910.119(i)(2)(ii): The pre-startup safety review did not confirm that prior to the introduction of highly hazardous chemicals to a process that Safety, operating, maintenance, and emergency procedures are in place and are adequate;    On June 9, 2015 and at times prior thereto and at subsequent times, the employer at Third Coast Terminals facility in Pearland, Texas, the employer did not ensure that operating and maintenance procedures were in place and adequate for the MEA Triazine process.    a) The employer did not ensure that an operating procedure for isolation of the scrubber from the reactor was in place.    b)The employer's preventive maintenance procedure was not adequate in that it requires isolation of the scrubber from the reactor but due to the absence of isolation valves this procedure does not define how such isolation is to be accomplished.    29CFR 1910.119(j)(2): The employer did not implement written procedures to maintain the on-going integrity of process equipment.    On June 9, 2015 and at times prior thereto and at subsequent times, in the MEA Triazine process area of the Third Coast Terminals facility in Pearland, Texas, the employer's written maintenance "SCRUBBERPM" task (as written) cannot safely be performed by the workers to whom the task was written.

Issued

2015-12-02 00:00:00

Abate by

2016-05-01 00:00:00

Penalty

Initial $6300.00 · Current $4500.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(5): Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation.    On or about June 9, 2015, and at times thereto, at Third Coast Terminals, Pearland, TX, in the MEA Triazine Unit, the employer failed to correct and or stop further use of damaged chemical hoses used to receive formaldehyde from incoming trucks for the MEA Trianzine Process. The damaged hoses had kinks and bulges, or soft spots on its exterior.

Issued

2015-12-02 00:00:00

Abate by

2016-05-01 00:00:00

Penalty

Initial $6300.00 · Current $6300.00

General-duty citation text

29 CFR 1910.119(j)(6)(i): In the construction of new plants and equipment, the employer shall assure that equipment as it is fabricated is suitable for the process application for which they will be used.    On June 9, 2015 and at the Third Coast Terminals facility in Pearland, Texas, the employer did not ensure that equipment for the new MEA Triazine process was suitable for the process application.    a) The employer did not perform a suitability for service analysis/evaluation of the reactor vessel.    b) The employer did not perform a suitability for service analysis/evaluation of the scrubber.    c) The employer did not perform a suitability for service analysis/evaluation of the heat exchanger.    d) The employer did not perform a relief study/analysis to ensure that the relief devices selected and employed in the process were adequate.    e) The employer did not ensure that welding standards and procedures were employed in fabrication of the piping for the MEA Triazine process.     f) The employer did not ensure that hoses selected for the MEA Triazine process were suitable for the process.

Issued

2015-12-02 00:00:00

Abate by

2016-05-01 00:00:00

Penalty

Initial $900.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process.    On June 9, 2015 and at times prior thereto and at subsequent times the employer's Piping and instrument diagram for the MEA Triazine process, at Third Coast Terminals, Inc in Pearland, TX, was inaccurate or incomplete:      a)  The reactor on the P&ID does not reflect a vent on the scrubber