OSHA Inspection: DOW CHEMICAL

Issued

Aug 22, 2016

Abate by

Mar 30, 2017

Penalty

Initial $5,345 · Current $5,345

General-duty citation text

29 CFR 1910.119(g)(1)(i):   Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks    On or around March 23, 2016 and at prior times and at times subsequent thereto, the training manual used by the employer at the Dow Chemical Company facility in Texas City, Texas to train and qualify operators for inside and outside operations jobs in the ESEOB Water Area of the Texas City Operations complex did not provide accurate representation and/or overview of the Cycle Water System.        a) The ESEOB Water Area Training Manual is inaccurate in its description of the Cycle Water System having eight (8) cooling towers.       b) The ESEOB Water Area Training Manual includes equipment that does not exist and is not supported by the water system.       c) The ESEOB Water Area Training Manual is inaccurate in describing the Cycle Water System as having seven (7) cooling towers on two plant loops, normally connected together, but capable of being isolated into the West Loop and East Loop.        d) The ESEOB Water Area Training Manual does not accurately present how cooling tower levels are controlled.       e) The ESEOB Water Area Training Manual is inaccurate in describing the Cycle Water System as having seven (7) cooling towers tied together with underground Cycle Water supply and return lines that allow the towers to float as one system with isolation valves that can be operated to separate the system into four major sections referred to as East Loop North, East Loop South, West Loop, and South Loop.

Issued

Aug 22, 2016

Abate by

Mar 30, 2017

Penalty

Initial $12,471 · Current $12,471

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information on paragraph (d) of this section) in a safe and timely manner when necessary means where taken to assure safe operation.    On or around March 23, 2016 and at times prior thereto, the employer at the Dow Chemical Company facility in Texas City, Texas allowed deficient equipment conditions that could have negative impact on the safety of covered processes to remain in place without ensuring measures were taken to ensure safe operation.       a) Isolation valves in the supply loop of the Cycle Water system are inoperable       b) Isolation valves in the return loop of the Cycle Water system are inoperable

Issued

Aug 22, 2016

Abate by

Mar 30, 2017

Penalty

Initial $12,471 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not establish and implement written procedures to manage changes  to process chemicals, technology, equipment,  and procedures; and, changes to facilities that affect a covered process.       On or around March 23, 2016 and at times prior thereto at the Dow Chemical Company facility on 5th Avenue South in Texas City, Texas, the employer did not manage changes to the Cycle Water System.       a) The employer  did not train employees on changes to the operating stem of the discharge isolation valve for the #5 cooling tower in the Cycle Water system.       b) The employer did not control changes to the isolation valves in the supply header loop of the Cycle Water System that impact the ability to isolate the supply header        c) The employer did not control changes to the isolation valves in the return header loop of the Cycle Water System that impact the ability to isolate the return header         d) Operating practice has changed such that the cooling tower levels are controlled in the control room at the control board but the training manual for operators has not been updated to reflect the change in operating practice.