OSHA Inspection: ULTRATEC SPECIAL EFFECTS, INC.

Issued

Mar 15, 2016

Abate by

Jan 30, 2017

Penalty

Initial $5,390 · Current $4,702 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): The employer did not include, in the process safety information compilation, the relief system design and the design basis:    (a) On or about 10/06/15 - at West Side Building A14, the employer did not include process safety information on the relief system design and design basis for the Styrofoam walls with aluminum sheathing and release latches.    (b) On or about 10/06/15 - at West Side Building A4, the employer did not include process safety information on the relief system design and design basis for the Styrofoam walls with aluminum sheathing and release latches.

Issued

Mar 15, 2016

Abate by

Jan 30, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(H): Process safety information pertaining to the equipment in the process did not include the safety systems (e.g., interlocks, detection or suppression systems):    (a) On or about 10/23/15 - at West Side Building A14 B room, the employer did not include process safety information for safety system equipment used in the process such as the humidity monitor for the building and the emergency stop switches and interlocked machine guards on the Hobart mixer.    (b) On or about 10/23/15 - at West Side Building A14 A room, the employer did not include process safety information for safety system equipment used in the process such as the emergency stop switches and interlocked machine guards on the Hobart chopper.

Issued

Mar 15, 2016

Abate by

Mar 30, 2017

Penalty

Initial $0 · Current $0

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 10/06/2015 - at West Side Building A14 B side, the employer failed to document compliance with recognized and generally accepted good engineering practices (RAGAGEP) to protect employees exposed to explosion and fire hazards.  One method of demonstrating RAGAGEP is compliance with standards as specified in National Fire Protection Association (NFPA) 70 National Electric Code and NFPA 1124 Code for the Manufacture, Transportation and Storage of Fireworks and Pyrotechnic Articles for modifications to the Hobart mixer.    (b) On or about 10/06/2015 - at West Side Building A14 A side, the employer failed to document compliance with recognized and generally accepted good engineering practices (RAGAGEP) to protect employees exposed to explosion and fire hazards.  One method of demonstrating RAGAGEP is compliance with standards as specified in National Fire Protection Association (NFPA) 70 National Electric Code and NFPA 1124 Code for the Manufacture, Transportation and Storage of Fireworks and Pyrotechnic Articles for modifications to the Hobart chopper.    (c) On or about 10/06/2015 - at West Side Building A6, the employer failed to document compliance with recognized and generally accepted good engineering practices (RAGAGEP) to protect employees exposed to explosion and fire hazards.  One method of demonstrating RAGAGEP is compliance with standards as specified in National Fire Protection Association (NFPA) 1124 Code for the Manufacture, Transportation, Storage, Retails Sales of Fireworks and Pyrotechnic Articles for posting the maximum weight of pyrotechnic and explosive composition permitted in each process building in that the posted limit on the outside of building A6 in two locations was "150LBS" and the "Maximum Allowable Energetic Weights" Memorandum for Record dated August 19, 2015 states the maximum limit is fifty (50) pounds.    (d) On or about 10/06/2015 - at West Side Building A14, the employer failed to document compliance with recognized and generally accepted good engineering practices (RAGAGEP) to protect employees exposed to explosion and fire hazards.  One method of demonstrating RAGAGEP is compliance with standards as specified in National Fire Protection Association (NFPA) 1124 Code for the Manufacture, Transportation, Storage, Retails Sales of Fireworks and Pyrotechnic Articles for posting the maximum weight of pyrotechnic and explosive composition permitted in each process building in that a limit was not posted and the "Maximum Allowable Energetic Weights" Memorandum for Record dated August 19, 2015 states the maximum limit is two hundred (210) pounds for 14a and sixty (60) pounds for 14b.    (e) On or about 10/06/2015 - at East Side Building B9, the employer failed to document compliance with recognized and generally accepted good engineering practices (RAGAGEP) to protect employees exposed to explosion and fire hazards.  One method of demonstrating RAGAGEP is compliance with standards as specified in National Fire Protection Association (NFPA) 1124 Code for the Manufacture, Transportation, Storage, Retails Sales of Fireworks and Pyrotechnic Articles for posting the maximum weight of pyrotechnic and explosive composition permitted in each process building in that a limit was not posted and the "Maximum Allowable Energetic Weights" Memorandum for Record dated August 19, 2015 does not identify a maximum limit for this building.

Issued

Mar 15, 2016

Abate by

Mar 30, 2017

Penalty

Initial $5,390 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(l)(4): Process safety information required by paragraph (d) of this section was not updated when a change covered by this paragraph resulted in a change in the process safety information:    (a) On or about 10/06/2015 - at West Side Building A14, Management of Change (MOC) identified as "Facility Addition A14 " dated June 2015 addressed refurbishing and putting into operation process building A14 and process safety information was not updated and available for the Hobart chopper, ventilation fan, scales, humidity/temperature gauge, interlocks, electrostatic discharge system (ESD), and relief system (blow-out walls and clamps).    (b) On or about 10/06/2015 - at West Side Building A6, MOC identified as "3" (inch) Comet press installed in A6" dated Sept 18, 2015 addressed movement and installation of 3" press in A6 and process safety information was not updated and available for the Comet Press, Comet ejector tool, and ESD.    (c) On or about 10/06/2015 - at West Side Building A4, MOC identified as "Process Change" dated May 2015 addressed Tracer Process Redesign and process safety information was not updated and available for the Tracer plates, Tracer ejector tool, ventilation fan and ESD.

Issued

Mar 15, 2016

Abate by

Jan 30, 2017

Penalty

Initial $5,390 · Current $5,390

General-duty citation text

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address the hazards related to facility siting:    (a) On or about 10/06/2015 - at 148 Moon Drive, Owens Cross Roads, AL, the initial process hazards analysis documented for processes, such as but not limited to Base Mix, did not address facility siting, such as but not limited to, explosive limits for each process building or area, distances between process buildings or areas, the consequences of a process failure on employees in other buildings or areas and employees traveling between buildings.

Issued

Mar 15, 2016

Abate by

Jan 30, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not address human factors:    (a) On or about 10/06/2015 - at 148 Moon Drive, Owens Cross Roads, AL, the initial process hazards analysis documented for processes, such as but not limited to Base Mix, did not address human factors, such as but not limited to, what would be the consequences and possible correcting methods for using incorrect ingredients, weighing ingredients incorrectly, and not following procedures.

Issued

Mar 15, 2016

Abate by

May 1, 2017

Penalty

Initial $5,390 · Current $5,390

General-duty citation text

29 CFR 1910.119(i)(1): The employer did not perform a pre-startup safety review for new facilities and for modified facilities when the modification was significant enough to require a change in the process safety information:    (a) On or about 10/06/2015 - at West Side Building A14, the employer did not complete a pre-startup safety review for the modified facility when electrical processing equipment was moved to the building, the relief system/blow-out walls were redesigned, and processes such as mixing base mix, nitrocellulose based nitrate composition and nitrocellulose based ammonium perchlorate composition  were relocated to the building.    (b) On or about 10/06/2015 - at West Side Building A4, the employer did not perform a pre-startup safety review for the new building when the Tracer and Strobe composition processes were relocated to the building.

Issued

Mar 15, 2016

Abate by

Mar 30, 2017

Penalty

Initial $5,390 · Current $2,890 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment:    (a) On or about 10/06/2015 - At West Side Buildings A2, A4, A5, A6, A7, A8, A11, A12, and A14, the employer failed to establish written procedures to maintain the mechanical integrity of relief system equipment in the process area such as ventilation system fans, weak wall relief panels, and humidity monitors.

Issued

Mar 15, 2016

Abate by

Jan 30, 2017

Penalty

Initial $2,618 · Current $2,618

General-duty citation text

29 CFR 1910.147(c)(4)(i): Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:    (a) On or about 10/06/2015 - at West Side Building A7, a procedure was not developed to control potentially hazardous energy, such as but not limited to hydraulics and pneumatics, when employees were changing the tooling in the 1-inch Comet Press exposing employees to caught-between and electrical hazards.

Issued

Mar 15, 2016

Abate by

Jan 30, 2017

Penalty

Initial $10,780 · Current $10,780

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 10/06/15 - at West Side Building A14 A Side, 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 Blue with Tail 3-inch nitrate pyrotechnic composition.  One method of demonstrating RAGAGEP is compliance with standards the company previously relied on such as the Army Safety Manual and NFPA 1124.     (b) On or about 2/6/15 - at West Side Building A14 A Side, 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 when manually screening Blue with Tail 3-inch nitrate pyrotechnic composition.  The wooden frame could not be grounded.  One method of demonstrating RAGAGEP is compliance with NFPA 77 on bonding and grounding for static protection.    Ultratec Special Effects, Inc. was previously cited for a violation of this occupational safety and health standard, which was contained in OSHA inspection number 1031388, citation number 1, item number 4 and was affirmed as a final order on 08/31/2015 with respect to a workplace located at 148 Moon Drive, Owens Cross Roads, AL 35763.

Issued

Mar 15, 2016

Abate by

Jan 30, 2017

Penalty

Initial $10,780 · Current $6,725 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 10/06/15 - at the West Side Building A14 A Side, the process hazard analysis for a PSM covered pyrotechnic process used to manufacture Base Mix was not updated and revalidated at least every five (5) years.  Since the initial process hazard analysis was validated on 02/09/10, the process has been relocated to building A14 and the equipment modified.    Ultratec Special Effects, Inc. was previously cited for a violation of this occupational safety and health standard, which was contained in OSHA inspection number 1031388, citation number 1, item number 6 and was affirmed as a final order on 08/31/2015 with respect to a workplace located at 148 Moon Drive, Owens Cross Roads, AL 35763.

Issued

Mar 15, 2016

Abate by

Jan 30, 2017

Penalty

Initial $10,780 · Current $6,725 Reduced

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 10/06/2015 - At West Side Building A14, a procedure was not developed to provided clear steps, safe operating limits, safety and health considerations, and identify safety systems and their functions for employees manufacturing the pyrotechnic composition "Blue with Tail Nitrate Mix".    (b) On or about 10/06/2015 - At West Side Building A14, a procedure was not developed to provided clear steps, safe operating limits, safety and health considerations, and identify safety systems and their functions for employees manufacturing the pyrotechnic composition "White w/ Silver Strobe 3-inch".    (c) On or about 10/06/2015 - At West Side Building A14, a procedure was not developed to provided clear steps, safe operating limits, safety and health considerations, and identify safety systems and their functions for employees manufacturing the pyrotechnic composition "Green Plain 3/16-inch AP".    (d) On or about 10/06/2015 - At West Side Building A14 and A2, the Base Mix Mixing Procedure SOP.M.081.15 dated 10/2015 was not clear for determining the assay value.    Ultratec Special Effects, Inc. was previously cited for a violation of this occupational safety and health standard, which was contained in OSHA inspection number 1031388, citation number 1, item number 7 and was affirmed as a final order on 08/31/2015 with respect to a workplace located at 148 Moon Drive, Owens Cross Roads, AL 35763.

Issued

Mar 15, 2016

Abate by

Jun 30, 2017

Penalty

Initial $10,780 · Current $10,780

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 10/06/2015 - at West side, a management of change was not implemented when the processing area identified as Zone 3 (Buildings A2 and A4 to A12) was changed to Zone 3A (Buildings A4-A12) and Zone 3B (Building A2/Drying Room) which increased the total energetic limits for Buildings A2 and A4 to A12.    (b) On or about 10/06/2015 - at East side, a management of change was not implemented when the Airburst process was moved from Building C12 to C2.    Ultratec Special Effects, Inc. was previously cited for a violation of this occupational safety and health standard, which was contained in OSHA inspection number 1031388, citation number 1, item number 8 and was affirmed as a final order on 08/31/2015 with respect to a workplace located at 148 Moon Drive, Owens Cross Roads, AL 35763.

Issued

Mar 15, 2016

Abate by

Mar 2, 2017

Penalty

Initial $0 · Current $0

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:    (a) On or about 10/06/2015 - at West Side Building A10, an incident report was not documented for the investigation of the February 2015 incident.

Issued

Mar 15, 2016

Abate by

Jun 30, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(c)(1): A written respiratory protection program that included the provisions in 29 CFR 1910.134(c)(1)(i) - (ix) with worksite specific procedures was not established and implemented for required respirator use:    (a) On or about 10/06/2015 - at West Side Building A2 southwest room, the employer did not have a written respiratory protection program for employees who are required to wear a disposable particulate respirator while operating the Hammer Mill to process Parlon (Chlorinated Rubber).

Issued

Mar 15, 2016

Abate by

Jun 30, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(c)(2)(ii): The employer did not establish and implement those elements of a written program necessary to ensure that any employee using a respirator voluntarily was medically able to use that respirator, and that the respirator was cleaned, stored, and maintained so that its use does not present a health hazard to the user:    (a) On or about 10/06/2015 - at West Side Building A4, the employer did not establish and implement the written program elements required for employees voluntarily using a half mask respirator with 3M 6001 cartridges when working with toluene.    (b) On or about 10/06/2015 - at West Side Building A6, the employer did not establish and implement the written program elements required for employees voluntarily using a half mask respirator with 3M 6001 cartridges when working with toluene.

Issued

Mar 15, 2016

Abate by

Jan 30, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.138(a): The employer did not select and require employee(s) to use appropriate hand protection when employees' hands were exposed to hazards such as those from skin absorption of harmful substances; severe cuts or lacerations; severe abrasion; punctures; chemical burns; thermal burns; and harmful temperature extremes:    (a) On or about 10/06/2015 - at West Side Building A6 and A14, employees mixing and processing various pyrotechnic compositions by hand were not wearing gloves when working with the following  chemicals: Nitrocellulose Wet with Water, Barium Carbonate, Copper Carbonate Basic, Strontium Carbonate, Potassium Perchlorate, Basic Copper Nitrate, Potassium Nitrate, Strontium nitrate, Magnesium Aluminum Alloy, Nitroguanidine wetted (with not less than 20% water), and Iron (III) Oxide. The material safety data sheets identified skin irritant as a hazard.

Issued

Mar 15, 2016

Abate by

Jan 30, 2017

Penalty

Initial $0 · Current $0

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 10/6/2015 - at West Side Building A2 Screening Room, the label's hazard statement on a bucket of Titanium Powder incorrectly stated "H225 - Highly flammable liquid and vapor".

Issued

Mar 15, 2016

Abate by

May 1, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(g)(1): Chemical manufacturers and importers did not obtain or develop a safety data sheet for each hazardous chemical and for each chemical that posed a hazard not otherwise classified that they produce or import:    (a) On or about 10/06/2015 - at 148 Moon Drive, Owens Cross Roads, AL, the employer did not develop safety data sheets for the following intermediate pyrotechnic compositions: nitrocellulose based ammonium perchlorate, nitrocellulose based nitrate, nitrocellulose base mix, Match Compositions (transfer comps, bridge comps), Prime Compositions (White Nitrate Prime, Red Gum Prime, Fuzzy Prime, Silicone Prime), Strobe Composition, Pixie Dust Glitter, Flitter Composition, Crossette Composition, Pyropack Gerb Composition, Sulfurless Prime, Quick Match, A/B, Powder Premixes (LT 100, LT 200) and final pyrotechnic products, such as but not limited to, ammonia perchlorate based comets and stars, nitrate based comets and stars, mixed A/B powders, tracers, fuses and matches as required by the standard.    (b) On or about 10/06/2015 - at 148 Moon Drive, Owens Cross Roads, AL, the employer did not develop safety data sheets for the final pyrotechnic products ,such as but not limited to, ammonia perchlorate based comets and stars, nitrate based comets and stars, mixed A/B powders, tracers, fuses and matches as required by the standard.

Issued

Mar 15, 2016

Abate by

May 1, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(1): The employer did not complete a compilation of the information pertaining to the hazards of the highly hazardous chemicals in the process. This information shall consist of at least the following as specified in (i to vii):    (a) On or about 10/06/2015 - at 148 Moon Drive, Owens Cross Roads, AL, the employer did not compile process safety information or safety data sheets for reactivity data of the intermediate pyrotechnic compositions, such as but not limited to, nitrocellulose based ammonium perchlorate, nitrocellulose based nitrate, nitrocellulose base mix, potassium perchlorate, gerb, specialty, tracer, mortar hit A/B, match, A/B powders, flame gel, prime, and fuse.      (b) On or about 10/06/2015 - at 148 Moon Drive, Owens Cross Roads, AL, the employer did not compile process safety information or safety data sheets for the reactivity data of the final pyrotechnic products, such as but not limited to, ammonia perchlorate based comets and stars, nitrate based comets and stars, mixed A/B powders, tracers, strobe, fuses and matches.