OSHA Inspection: BUFFALO CARTRIDGE COMPANY, INC.

Issued

Aug 1, 2017

Abate by

Aug 24, 2017

Penalty

Initial $406 · Current $0 Reduced

General-duty citation text

29 CFR 1903.19(d)(1): The employer did not submit to the Agency, along with the information on abatement certification required by paragraph (c)(3) of this section, documents demonstrating that abatement was complete for each willful or repeat violation and for any serious violation for which the Agency indicates in the citation that such abatement documentation is required:    Buffalo Cartridge Company, Inc. - On or about August 1, 2017, the employer did not provide abatement documentation for citation 1, items 5a and 5b, which became a final order on October 28, 2016.

Issued

Oct 4, 2016

Abate by

May 19, 2017

Penalty

Initial $3,563 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(c)(1): Employers did not develop a written plan of action regarding the implementation of the employee participation required by this paragraph.    a. Buffalo Cartridge Company, Inc. located in Findlay, Ohio:  On or about May 26, 2016, the employer did not develop an employee participation plan of action which explains how employees will be consulted regarding the development of all elements of process safety management.

Issued

Oct 4, 2016

Abate by

May 19, 2017

Penalty

Initial $3,563 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d): In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer did not complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information did not include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.    a. Buffalo Cartridge Company, Inc. located in Findlay, Ohio:  On or about May 26, 2016, the employer did not ensure process safety information included information on the following:    1. Process chemistry;    2. Maximum Intended inventory;    3. Safe upper and lower limits such as temperature, feed rates, maximum and minimum quantities of materials in automatic loader hoppers;    4. An evaluation of the consequences of deviations;    5. Electrical classification of the areas around the automatic loaders;    6. Safety systems on the automatic loaders.

Issued

Oct 4, 2016

Abate by

May 19, 2017

Penalty

Initial $3,563 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(1): The employer did not perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis was not appropriate to the complexity of the process and did not identify, evaluate, and control the hazards involved in the process. Employers did not determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process.     a. Buffalo Cartridge Company, Inc. located in Findlay, Ohio:  On or about May 26, 2016, the employer did not perform a process hazard analysis for the ammunition reloading operation. Hazards such as but not limited to the following need to be addressed:        1. Clean-up of smokeless powder from floors and equipment;        2. Clean-up of primer powder from feeding tubes and reservoirs;        3. Normal operation of automatic loading machines;        4. Handle primers that have dropped onto the floor;        5. Clean-up before maintenance activities;        6. Unjamming of primers from primer tubes;        7. Build-up of static electricity on the employee and equipment.    b. Buffalo Cartridge Company, Inc. located in Findlay, Ohio:  On or about May 26, 2016, the employer did not perform a process hazard analysis for the handling and storage of smokeless powder and primers.  Hazards such as but not limited to the following need to be addressed:        1. Storage of bad or waste smokeless powder.;        2. Handling and storage of primers and smokeless powder.    c. Buffalo Cartridge Company, Inc. located in Findlay, Ohio:  On or about May 26, 2016, the employer did not perform a process hazard analysis to address human factors associated with the automatic loading equipment.  Human factors include but are not limited to:        1. Improper sequence of or failure to perform operational steps        2. Incorrect amount of flammable or explosive material        3. Lack of experience for loading machine operators        4. Lack of or ineffective training for loading machine operators         5. Fatigue        6. Environmental issues (lighting, temperature, noise, distractions)        7. Inadequate supervision        8. Human/equipment interaction        9. High work load        10. Lack of/ quality of procedures        11. Operational displays and controls accessibility        12. Repetitious tasks        13. Types of clothing to worn by loading machine operators.    d. Buffalo Cartridge Company, Inc. located in Findlay, Ohio:  On or about May 26, 2016, the employer did not perform a process hazard analysis to address facility siting associated with the automatic loading equipment.  Facility siting hazards include but are not limited to:        1. Distance between automatic loading machines and the fire hazards of one machine affecting the safety of adjacent equipment.

Issued

Oct 4, 2016

Abate by

May 19, 2017

Penalty

Initial $3,563 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1): The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements.    a. Buffalo Cartridge Company, Inc. located in Findlay, Ohio:  On or about May 26, 2016, the employer did not establish operating procedures for the operations: such as but not limited to the following:        1. Clean-up of smokeless powder from floors and equipment;        2. Clean-up of primer powder from feeding tubes and reservoirs;        3. Normal operation of automatic loading machines;        4. Handling  and storage of primers;        5. Handling and storage of smokeless powder;        6. Handling and storage of bad or waste smokeless powder;        7. How to check for bad smokeless powder;        8. How to handle primers that have dropped onto the floor;        9. Clean-up of equipment before maintenance activities;        10. Unjamming of primers from primer tubes.

Issued

Oct 4, 2016

Abate by

May 19, 2017

Penalty

Initial $3,563 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment.    a. Buffalo Cartridge Company, Inc. located in Findlay, Ohio:  On or about May 26, 2016, the employer did not establish and implement written procedures to ensure loading stations were properly grounded and bonded to protect against static electricity build-up.    b. Buffalo Cartridge Company, Inc. located in Findlay, Ohio:  On or about May 26, 2016, the employer did not establish and implement written procedures to ensure the integrity of the facility's fire suppression system.

Issued

Oct 4, 2016

Abate by

May 19, 2017

Penalty

Initial $3,563 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): Inspections and tests were not performed on process equipment.    a. Buffalo Cartridge Company, Inc. located in Findlay, Ohio:  On or about May 26, 2016, the employer did not ensure inspection and testing was performed on the Camdex automatic reloaders to ensure the equipment was protected from the accumulation of static build-up.

Issued

Oct 4, 2016

Abate by

May 19, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.    a. Buffalo Cartridge Company, Inc. located in Findlay, Ohio:  On or about May 26, 2016, the employer did not establish and implement written procedures to manage changes in the process chemicals, technology, equipment, procedures, or the facility.