OSHA Inspection: CHS, INC.

Issued

Mar 24, 2016

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the team's findings and recommendations; assure that the recommendations were resolved in a timely manner with documented resolutions; document the actions that were to be taken; complete actions as soon as possible; develop a written schedule of action completion dates; or communicate the actions to operating maintenance, and other employees working in the process areas or who may have been affected by the recommendations or actions.    On or about October 23, 2015, a review of the PSM program found employees engaged in ethanol production were exposed to the ongoing hazard associated with the potential catastrophic release of highly hazardous chemicals and the employer's 2008 and 2012 PHAs did not establish a system to address the findings and ensure their completion in a timely manner with documented resolutions including the actions taken.

Issued

Mar 24, 2016

Abate by

May 10, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(m)(4)(v): At conclusion of the incident investigation, the report did not include any recommendations resulting from the investigation.    On or about October 23, 2015, a review of incident investigation reports found employees engaged in ethanol production were exposed to the ongoing hazard of a potential release of a highly hazardous chemical and the employer's incident investigation report did not include any recommendations resulting from the investigation: In the incident report dated 12-19-14, an ammonia delivery driver was unloading ammonia without following procedures due to unsecured locks. The incident investigation report identified contributing factors and root causes but did not contain any recommendations or prevent recurrence of the incident.

Issued

Mar 24, 2016

Abate by

May 10, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(m)(5): The employer did not establish a system to promptly address and resolve incident report findings.    On or about October 23, 2015, a review of incident investigation reports found employees engaged in ethanol production were exposed to the ongoing hazard of a potential release of a highly hazardous chemical and the employer did not promptly address and resolve incident report findings and recommendations and the resolutions and corrective actions were not documented in the incident investigations:    a) The incident report of 12-19-14 identified contributing factors and root causes but did not have any documented recommendations. The report had no documentation of resolutions and corrective actions or other documentation that addressed and resolved incident findings.     b) The incident report of 06-10-14 identified work habits and maintenance issues as contributing factors and root causes. Operator retraining was identified a recommendation, there was no recommendations related to maintenance findings and there was no documentation of resolutions or corrective actions.       c) The incident report of 07-31-15 identified work standards/procedures and knowledge/skills as contributing factors to the incident and documented recommendations. Only one of the three resolutions and corrective actions was documented as completed.     d) The incident report of 10-27-15 identified numerous findings and recommendations. Several of the recommendations did not have resolutions or corrective actions documented or any other documentation that addressed and resolved the findings.       e) The incident report of 05/28/15 identified training as a contributing factor and recommended that employees be retrained in ammonia unloading procedures. The resolution and corrective actions taken for the recommendations were not documented.

Issued

Mar 24, 2016

Abate by

May 10, 2016

Penalty

Initial $5,000 · Current $5,000

General-duty citation text

29 CFR 1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies had been corrected:   On or about October 23, 2015, a review of compliance audit reports found employees engaged in ethanol production were exposed to the ongoing hazard of a potential release of a highly hazardous chemical and the employer had not determined responses and documented that deficiencies had been corrected.  a) The employer completed a compliance audit on September 7-8, 2011 in the ethanol unit.Several of the audit criteria were identified as 'not in compliance wit the stated criteria' and in each case a finding and recommended corrective action was provided. The employer did not document that each deficiency from the 2011 audit had been corrected, including, but not limited to, P11 - Incident Investigations sublevel 1.1.5. developing comprehensive corrective action tracking system for all incident findings and recommendations.    b) The employer completed a compliance audit on November 12-14, 2014 in the ethanol unit. Several of the audit criteria were identified as 'not in compliance wit the stated criteria' and in each case a finding and recommended corrective action was provided. The employer did not document that each deficiency from the 2014 audit had been corrected, including, but not limited to, P11 - Incident Investigations sublevel 1.1.5. developing comprehensive corrective action tracking system for all incident findings and recommendations.