OSHA Inspection: DELTECH RESIN COMPANY

Issued

Dec 27, 2016

Abate by

Feb 9, 2019

Penalty

Initial $8,730 · Current $6,250 Reduced

General-duty citation text

29 CFR 1910.119(c)(1): The employer did not develop a written plan of action regarding the implementation of the employee participation required by 29 CFR 1910.119:    a) Building 3 - alkyd resin process for 537-50X    The employer's written plan of action for employee participation in process safety management did not include the alkyd resin process.  On 6/29/16 the company made an 11,699 pound batch of 537-50X, a flammable liquid with a flash point of 78 F.      Violation occurred on or about 6/29/16.

Issued

Dec 27, 2016

Abate by

Feb 9, 2019

Penalty

Initial $8,730 · Current $6,250 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): Information pertaining to the equipment in the process did not include piping and instrument diagrams (P&ID's):    a) Establishment - Building 3, alkyd resin process    The employer did not ensure that the written process safety information included all the necessary information pertaining to the equipment in the process when basic data such as, but not limited to, vessel size, piping material specifications, equipment numbers, rupture disk burst pressure and failure modes of automatic valves were not included in PID 13-82-H-23.      b) Establishment - Building 3, alkyd reactor AR-1    The employer did not ensure that written process safety information accurately reflected existing equipment in the process in that PID 13-82-H-23 did not show a manual valve on top of the condenser for AR-1, a gate valve on the AR-1 line to its decanter and a temperature gauge on the cooling water supply line to AR-1.    c) Establishment - Building 3, alkyd reactor AR-1    The employer did not ensure that written process safety information accurately reflected existing equipment in the process in that PID 13-82-H-23 showed 1) a 4 inch line at the top of a condenser reduced to 3 inches, a tee and reducer to a 2 inch line that is connected by flexible tubing to the header to the scrubber rather than smaller diameter piping hard piped to the header and 2) a 12 inch line from the reactor to the condenser rather than an 8 inch line.     Violations occurred on or about 6/29/16.

Issued

Dec 27, 2016

Abate by

Feb 9, 2019

Penalty

Initial $8,730 · Current $6,250 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 29 CFR 1910.119:     a)  Building 3 - alkyd resin process    The employer did not perform a process hazard analysis on its process for flammable alkyd resins made in batches over 10,000 pounds.  On 6/29/16 the company made an 11,023 pound batch of product 537-50X, a flammable liquid with a flash point of 78 F.     Violation occurred on or about 6/29/16.

Issued

Dec 27, 2016

Abate by

Feb 9, 2019

Penalty

Initial $8,730 · Current $6,250 Reduced

General-duty citation text

29 CFR 1910.119(f)(1): 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 and addressing at least steps for each operating phase, safe operating limits, safety and health considerations, and safety systems and their functions as outlined by this paragraph:    a) Building 3-alkyd resin process for 537-50X    The employer's written operating procedures for the alkyd resin process which consisted of batch cards did not address all operating phases such as  initial startup, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup following a turnaround.    Violation occurred on or about 6/29/16.

Issued

Dec 27, 2016

Abate by

Feb 9, 2019

Penalty

Initial $8,730 · Current $6,250 Reduced

General-duty citation text

29 CFR 1910.119(g)(2):  Refresher training was not provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understood and adhered to the current operating procedures of the process.      a) Building 3 - alkyd resin 537-50X process    Employees involved in the manufacture of alkyd resin 537-50X were not provided with refresher training on current operating procedures.  On 6/29/16 the company made an 11,699 pound batch of 537-50X, a flammable liquid with a flash point of 78 F.      Violation occurred on or about 6/29/16.      b)  Building 3 - urethane resin 372-60X    Employees involved in the manufacture of alkyd resin 372-60X were not provided with refresher training on current operating procedures.  On 8/2/16 the company made an 12,921 pound batch of 372-60X, a flammable liquid with a flash point of 78 F.    Violation occurred on or about 8/2/16

Issued

Dec 27, 2016

Abate by

Feb 9, 2019

Penalty

Initial $8,730 · Current $6,250 Reduced

General-duty citation text

29 CFR 1910.119(h)(2)(iv): The employer did not develop and implement safe work practices consistent with paragraph (f)(4) of this section to control the entrance, presence and exit of contract employers and contract employees in the covered process areas.    a)  Production Building 3.    The employer failed to verify that employees of contractor L&L Mechanical signed in or out when working on valve and piping replacement on the first floor of the production building.    Violation occurred on or about 9/23/16.    b)  Production Building 3.    The employer failed to verify that employees of contractor L&L Mechanical signed in or out when working on valve and piping replacement on the first floor of the production building .    Violation occurred on or about 9/24/16.

Issued

Dec 27, 2016

Abate by

Feb 9, 2019

Penalty

Initial $8,730 · Current $6,250 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) Building 3 - alkyd resin process for 537-50X    The employer did not establish and implement written procedures for the maintenance, inspection and testing of equipment used in the manufacture of flammable alkyd resins in batches over 10,000 pounds including but not limited to alkyd reactor AR1, condenser, decanter; thinning tank AT21, filter presses, associated pumps, piping and appurtenances.               Violation occurred on or about 6/29/16.

Issued

Dec 27, 2016

Abate by

Feb 9, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4): The employer did not perform inspection and testing on process equipment:    a) Building 3 - alkyd resin process for 537-50X    The employer failed to perform inspection and testing of equipment such as but not limited to alkyd reactor AR1, condenser, decanter; thinning tank AT21, filter presses, associated pumps, piping and appurtenances used in the manufacture of flammable alkyd resins in batches over 10,000 pounds.                  Violation occurred on or about 6/29/16.

Issued

Dec 27, 2016

Abate by

Feb 9, 2019

Penalty

Initial $8,730 · Current $6,250 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not certify that they had evaluated compliance with provisions of 29 CFR 1910.119 at least every three years to verify that the procedures and practices developed under this standard were adequate and are being followed:     a) Building 3 - alkyd resin process for 537-50X    The employer did not perform compliance audits on their alkyd resin process for flammable resins in batches over 10,000 pounds.                  Violation occurred on or about 6/29/16.