OSHA Inspection: WORTHINGTON INDUSTRIES

Issued

Nov 17, 2015

Abate by

Dec 31, 2016

Penalty

Initial $7,000 · Current $7,000

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.      At the Chilton, WI facility the employer's piping and instrument diagram (P&ID) was not accurate and did not represent equipment that was existing and was part of the propane/propylene process safety management (PSM) covered system including, but not limited to, the following instances:      a)  Equipment documented on the P&ID did not exist on the system. Approximately 47 pieces of equipment were identified on the P&ID which could not be found on the propane/propylene system including, but not limited to:       1) Pressure safety valves (PRV)       2) Valves including ball valves, globe valves, flow indicating check valves, and inline check valves       3) Branches on the system with valves or dead ends       4) Stainless steel flexible lines      b)  Equipment on the system was not identified, was incorrectly identified or identification was inadequate. Approximately 93 pieces of equipment were either; not identified with a tag/number, were identified with the incorrect tag/number, or the identifying tag/number was illegible      c)  Equipment which existed on the system was not documented on the P&ID.  Approximately 45 pieces of equipment which were installed and in operation on the system were not documented on the P&ID including, but not limited to:       1) Capped dead end portions of piping       2) Tee fittings with plugs       3) Valves including globe valves, ball valves, angle valves, a gate valve, an isolation valve, and a stem valve       4) Gages including pressure gages, a volume gage and a temperature gage       5) Pressure relief valves (PRV)       6) Stainless steel flexible lines       7) Sections of active piping        d)  Equipment's location/position on the system was not correctly documented on the P&ID. Approximately ten sections of P&ID were not drawn to represent the actual layout of equipment on the system, including but not limited to:       1) Equipment drawn in the wrong positions relative to other equipment such as valves, PRV's, strainers, a compressor and a stainless steel flexible line       2) Tee sections of piping drawn as straight sections of piping      e)  Equipment on the P&ID was documented with duplicate identification of equipment. Approximately two instances on the P&ID identified sets of equipment with the same identification tag/number including, but not limited to:       1) Check valves       2) Angle valves with PRV's      f)  Equipment on the P&ID was not documented with the equipment's designation type. Approximately ten pieces of equipment were drawn on the P&ID; however, the two-to-three digit number representing those equipment's make/model were not documented on the P&ID including, but not limited to:       1) Strainers with valves       2) Pressure relief valves (PRV)       3) Stainless steel flexible lines       4) A black rubber transfer hose       5) Ball valves      g)  Equipment on the P&ID was documented with incorrect designation type. Approximately 15 pieces of equipment were identified on the P&ID with the incorrect two-to-three digit number representing the equipment's make/model including, but not limited to:      1) Valves including angle valves, globe valves, ball valves, and needle valves      2) A Corken compressor

Issued

Nov 17, 2015

Abate by

Mar 31, 2016

Penalty

Initial $0 · Current $1,500

General-duty citation text

29 CFR 1910.119(f)(3): The operating procedures were not reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer did not annually certify that operating procedures were current and accurate:    a)  At the Chilton, WI facility, the employer had not annually certified the "Rail Tank Car Unloading Procedure/Checklist" SOP since April of 2014 and did not review it to assure that it reflected current operating practices, such as but not limited to, exceeding  the SOP's stated "Maximum Propylene tank capacity".

Issued

Nov 17, 2015

Abate by

Feb 7, 2016

Penalty

Initial $5,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not establish or implement 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 06/25/2015 at the Chilton, WI facility, the employer had not implemented written procedures to managed changes to the standard operating procedure (SOP) titled "Rail Tank Car Unloading Procedure/Checklist" when laborer employees were directed by the employer to deviate from the "Maximum Propylene tank capacity" of 81%. The employer had not conducted any management of change procedures when the No. 1 Propylene tank was filled beyond 81%.

Issued

Nov 17, 2015

Abate by

Feb 7, 2016

Penalty

Initial $7,000 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(B): The employer's written operating procedures covering operating limits did not address the steps required to correct of avoid deviation:    a)  On or about 06/25/2015 at the Chilton, WI facility, the employer's standard operating procedure (SOP) titled "Rail Tank Car Unloading Procedure/Checklist" did not address the steps required to correct or avoid deviations of operating limits. The employer directed workers to deviate from the operating procedure and fill the propylene tank to levels of 82-95% when the SOP stated the maximum propylene tank capacity was listed as 81%.

Issued

Nov 17, 2015

Abate by

Jun 30, 2016

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(m)(4): An incident report was not prepared at the conclusion of the investigation that included at a minimum, the date of the incident, date the investigation began, a description of the incident, and any recommendations resulting from the investigation:    At the Chilton, WI facility, the employer had not prepared incident reports at the conclusion of investigations that included at a minimum, the date of the incident, date the investigation began, a description of the incident, and any recommendations resulting from the investigations of:     a)  On or about 08/01/2015, nitrogen from the emergency shut-off valve leaked through a crack in the regulator diaphragm which caused an over pressurization of the system resulting in a pressure relief valve actuating to release gasses from the over pressured line.    b)  On or about 07/08/2015, packing of Union Pump #1 failed and flammable gasses escaped the system into the fill building where the MSA sensor "head" was triggered and caused the emergency shutdown to activate.

Issued

Nov 17, 2015

Abate by

Mar 31, 2016

Penalty

Initial $7,000 · Current $1,500 Reduced

General-duty citation text

29 CFR 1910.119(n): The emergency action plan did not include procedures for handling small releases:    a)  At the Chilton, WI facility, the employer's Emergency Contingency Plan (ECP) did not include distinctions of small versus large releases of flammable chemicals such as propane and propylene nor did it include procedures for handling small releases.

Issued

Nov 17, 2015

Abate by

Dec 28, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F): Information pertaining to the equipment and process did not include design codes and standards that were employed:  At the Chilton, WI facility, the employer did not list all design codes and standards that were employed in the company's PSM program under Attachment 8-1 "Design Codes & Standards":  a)  The employer's list of design codes and standards did not include NFPA 1 "Uniform Fire Code" which was employed in the design, operation and maintenance of the fill building's flammable dilution ventilation engineering control.   b)  The employer's list of design codes and standards did not include NFPA 25 "Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems" which was employed in the design, operation and maintenance of the fill building's fire detection and deluge systems.

Issued

Jun 29, 2015

Abate by

Jul 22, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1904.29(b)(1): A Log of all recordable work-related injuries and illnesses (OSHA Form 300 or equivalent) was not completed in the detail as required by the regulation:  The employer, Worthington Industries, located at 300 East Breed Street, Chilton, WI,  did not complete the details as required by this regulation for the work-related injury or illness descriptions required in column F of the employer's 2015 OSHA Form 300:  a)  On or about 01/05/2015, a Production Operator was injured.  Case No. 2015-WCCHI-004 did not include a description of the injury or illness in Column F and only contained the word "Contested".  b)  On or about 01/13/2015, a Production Operator was injured.  Case No. 2015-WCCHI-009 did not include a description of the injury or illness in Column F and only contained the word "Contested".  c)  On or about 02/17/2015, a Maintenance employee was injured.  Case No. 2015-WCCHI-029 did not include a description of the injury or illness in Column F and only contained the word "Contested".

Issued

Jun 29, 2015

Abate by

Jul 22, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1904.29(b)(2): The employer did not fill out or correctly fill out an OSHA Form 301 or equivalent for each recordable injury or illness.  The employer did not complete the details as required by this regulation for the injury or illness descriptions required in line 16 of two 2015 OSHA 301 forms:  a)  On or about 01/05/2015, the employer did not complete a 301 form for Case No. 2015-WCCHI-004 when a Production Operator employee was injured.    b)  On or about 01/13/2015, the employer did not complete a 301 form for Case  No. 2015-WCCHI-029 when a Production Operator employee was injured.