OSHA Inspection: RUST-OLEUM CORPORATION

Issued

Jan 20, 2016

Abate by

Mar 8, 2016

Penalty

Initial $7,000 · Current $4,900 Reduced

General-duty citation text

29 CFR 1910.119(e)(3): The process hazard analysis did not address the elements of (i) through (vii) of this paragraph:    a) 173 Belmont Drive,  Somerset, NJ site - Shellac Department:     The initial process hazard analysis (PHA) was developed in March 1995. The PHA failed to address all of the elements of (i) through (vii) of this paragraph such as but not limited to:     (iv) Consequences of failure of engineering and administrative controls;  (v) Facility siting;   (vi) Human factors; and/or  (vii) A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace.    Conditions noted on or about 8/4/2015.

Issued

Jan 20, 2016

Abate by

Mar 8, 2016

Penalty

Initial $0 · Current $0

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) 173 Belmont Drive,  Somerset, NJ site - Shellac Department:   The initial process hazard analysis (PHA) was developed in March 1995. The employer has not performed a PHA revalidation since the completion of the initial PHA.  Conditions noted on or about 8/4/2015.

Issued

Jan 20, 2016

Abate by

Mar 8, 2016

Penalty

Initial $5,500 · Current $3,850 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish or implement written procedures to maintain the on-going integrity of process equipment    a) 173 Belmont Dr. Somerset, NJ site - Shellac Department above ground transfer piping:     The employer's existing procedures were not completely developed, in that, they did not include on-stream inspection procedures.     Condition noted on or about 8/4/2015.

Issued

Jan 20, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(ii): Inspections and testing procedures performed on process equipment to maintain their mechanical integrity did not follow recognized and generally accepted good engineering practices (RAGAGEP):  a) 173 Belmont Dr. Somerset, NJ site - Shellac Department above ground transfer piping:   The employers inspection and testing procedures did not follow RAGAGEP such as, but not limited to, 2013 National Board Inspection Code (NBIC) 4.4.7 DETERMINING INSPECTION INTERVALS, when they failed to perform a baseline thickness measurement and establish inspection intervals for the above ground piping lines leading from the ethyl alcohol storage tank to the indoor processing tanks..   Condition noted on or about 8/4/2015.

Issued

Jan 20, 2016

Abate by

Mar 8, 2016

Penalty

Initial $4,400 · Current $3,080 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) 173 Belmont Drive,  Somerset, NJ site - Shellac Department:     The employer failed to perform an audit to evaluate compliance with the provisions of section (o) at least every three (3) years.    Conditions noted on or about 8/4/2015.

Issued

Jan 20, 2016

Penalty

Initial $5,500 · Current $3,850 Reduced

General-duty citation text

29 CFR 1910.212(a)(1): One or more methods of machine guarding was not provided to protect the operator and other employees in the machine area from hazards such as those created by moving parts of conveyors and rotating parts:    a) 173 Belmont Drive,  Somerset, NJ site - Shipping Area:     The moving rollers located along the conveyor belt system were not guarded to prevent employees clothing and/or hair from accidentally being caught in the in-running nip points during operation.    Condition noted on or about 8/4/2015.

Issued

Jan 20, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.212(a)(3)(ii): Point(s) of operation of machinery were not guarded to prevent employee(s) from having any part of their body in the danger zone(s) during operating cycle(s):  a) 173 Belmont Drive,  Somerset, NJ site - Shipping Area:   The blue American International cardboard compactor (Model# HL600HD S/N: 92-1218) was not adequately guarded to prevent accidental contact with the point of operation during the operating cycle.  Condition noted on or about 7/22/2015.