OSHA Inspection: OSRAM SYLVANIA, INC.

Issued

Feb 26, 2016

Abate by

Apr 13, 2016

Penalty

Initial $5,000 · Current $3,750 Reduced

Hazardous substances 2290

General-duty citation text

29 CFR 1910.119(d)(2)(i)(D): Information concerning the technology of the process did not include safe upper and lower limits for such items as temperatures, pressures, flows or compositions.      a.) Osram Sylvania, Inc. - On or about October 23, 2015, and at times prior thereto, the employer's process safety information did not include safe upper and lower operating limits for operating pressures for the Sulfur Dioxide (SO2) system.

Issued

Feb 26, 2016

Abate by

May 31, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 2290

General-duty citation text

29 CFR 1910.119(d)(3)(i)(A): Process safety information pertaining to the equipment in the process did not include materials of construction:      a.) Osram Sylvania, Inc. - On or about October 23, 2015, and at times prior thereto, the employer's process safety information for the Sulfur Dioxide (SO2) system did not include the materials of construction (i.e. types of piping) that were used.

Issued

Feb 26, 2016

Abate by

May 31, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 2290

General-duty citation text

29 CFR 1910.119(d)(3)(i)(E): Information pertaining to the equipment in the process did not include the ventilation system design.      a.) Osram Sylvania, Inc. - On or about October 23, 2015, and at times prior thereto, the employer's process safety information for the Sulfur Dioxide (SO2) storage room did not include the ventilation system design.

Issued

Feb 26, 2016

Abate by

May 31, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 2290

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F): Information pertaining to the equipment in the process did not include design codes and standards that were employed.    a.) Osram Sylvania, Inc. - On or about October 23, 2015, and at times prior thereto, the employer's process safety information for the Sulfur Dioxide (SO2) system did not include design codes and standards for equipment  (i.e. piping, valves, SO2 tank heater) that was part of the system.

Issued

Feb 26, 2016

Abate by

May 31, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 2290

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.) Osram Sylvania, Inc. - On or about October 23, 2015, and at times prior thereto, the employer's process safety information for the Sulfur Dioxide (SO2) system did not include safety systems (including valves on piping), relief systems, and controls (including monitoring devices, sensors and alarms).

Issued

Feb 26, 2016

Abate by

Apr 13, 2016

Penalty

Initial $5,000 · Current $3,750 Reduced

Hazardous substances 2290

General-duty citation text

29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not address the consequences of failure of engineering and administrative controls:    a.) Osram Sylvania, Inc. - On or about October 23, 2015, and at times prior thereto, the employer's process hazard analysis failed to properly evaluate the consequences of failure of engineering and administrative controls of the Sulfur Dioxide (SO2) leak detection system. The alarm could be triggered without employee knowledge, if employees were not working near the SO2 storage room where the SO2 monitor is located. In the event of such occurrence, employees may not have sufficient time to take evasive and corrective actions resulting in employee exposure to SO2.

Issued

Feb 26, 2016

Abate by

May 31, 2016

Penalty

Initial $5,000 · Current $3,750 Reduced

Hazardous substances 2290

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.) Osram Sylvania, Inc. - On or about October 23, 2015, and at times prior thereto, the written Mechanical Integrity Program did not include information including, but not limited to, the frequency of inspections and tests for piping systems (including valves on piping), relief and ventilation systems, and controls (including monitoring devices, sensors, and alarms).

Issued

Feb 26, 2016

Abate by

May 31, 2016

Penalty

Initial $5,000 · Current $3,750 Reduced

Hazardous substances 2290

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.) Osram Sylvania, Inc. - On or about October 23, 2015, and at times prior thereto, the employer did not prepare written incident investigation reports following investigations that occurred after the activation of the Sulfur Dioxide (SO2)alarm/detector located in the SO2 storage room.

Issued

Feb 26, 2016

Abate by

Apr 13, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 2290

General-duty citation text

29 CFR 1910.119(n): The employer's emergency action plan did not include procedures for handling small releases:         a.) Osram Sylvania, Inc. - On or about October 23, 2015, and at times prior thereto, the employer's emergency action plan (EAP) did not include procedures for handling small releases of Sulfur Dioxide (SO2). Additionally, the EAP did not define a small release or a large release of SO2.

Issued

Feb 26, 2016

Abate by

Apr 13, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 2290

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not document the resolution of PHA recommendations:   a.) Osram Sylvania, Inc. - On or about October 23, 2015, and at times prior thereto, resolutions to findings from the 2013 process hazard analysis had not been not been documented. Resolutions to findings including, but not limited to "Look into more frequent crane/hoist inspections" and "Develop replacement process for addressing possible PSM process changes" had not been documented.