OSHA Inspection: LIGNOTECH USA INC.

Issued

Dec 20, 2016

Abate by

Jan 31, 2017

Penalty

Initial $4,988 · Current $400 Reduced

Hazardous substances 1290

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)  On or about August 31, 2016, the employer had not compiled written process safety information concerning the technology of the process including safe upper and lower limits for such items as temperature, pressure, or compositions for equipment such as, but not limited to; 9000 gallon formaldehyde storage tank, B5 reactor tank, B6 reactor tank and B7 reactor tank.

Issued

Dec 20, 2016

Penalty

Initial $4,988 · Current $400 Reduced

Hazardous substances 1290

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:    On or about August 31, 2016, the employer had not compiled process safety information pertaining to the materials of construction for the formaldehyde system piping including:    a)  The fixed piping material (316 stainless steel), pipe schedule number (Schedule 40), its nominal pipe size (2 inches to 1/2 inch), its outside diameter (2.375 inches to 0.840 inches) or its wall thickness of the pipe (0.154 inches to 0.109 inches). This piping was used for regular transfer of formaldehyde into and throughout the system.    b)  The Plicord 250 Steam industrial hose material (Black EMPD synthetic rubber reinforced with spiral-plied steel wire), its temperature range (0 F to 406 F), its inside diameter, its nominal size, and its max pressure. This industrial hose was used for irregular cleaning of the formaldehyde storage tank.

Issued

Dec 20, 2016

Abate by

Jan 31, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer did not develop piping and instrument diagrams for the equipment that was part of the process:  On or about August 31, 2016, the employer's piping and instrument diagrams (P&ID) did not clearly identify the equipment that was part of the formaldehyde process system including, but not limited to: piping (from 2" to 1/2"), cam and groove connection, ball valves (from 2" to 1/2"), air blow-offs/drains, auto-fill valve, storage tank, I to P pressure sensors, D/P cell level sensors, auto-vent valve, formaldehyde system pump, heat tracer, auto-metering valve, pipe step downs, water lines, flow meter, pressure gage, air lines, inline orifice, dead-ended lines/caps/plugs, formaldehyde process tanks, and control system (PLC) and its connections to some of the aforementioned equipment.

Issued

Dec 20, 2016

Abate by

Jan 31, 2017

Penalty

Initial $4,988 · Current $3,492 Reduced

Hazardous substances 1290

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not develop a written schedule of actions to resolve PHA recommendations, did not document what actions were to be taken to resolve PHA recommendations, and did not document the resolution of the PHA recommendations:    On or about August 31, 2016, the employer had not developed a written schedule of actions to resolve PHA recommendations, had not documented what actions were to be taken to resolve PHA recommendations, and did not document the resolution of the PHA recommendations when:    a)  The 2015 PHA resulted in three (3) recommendations including; add storage room leak checks to the Formaldehyde System Process Operating Manual and Formaldehyde Unloading Procedure, investigate adding an alarm to the heat trace, and have management conduct standardized baseline training for Chemical Process Operators (CPOs).    b)  The 2010 PHA resulted in one (1) recommendation which was to add a warning to the formaldehyde transfer procedure to close manual transfer valves in the event of a power failure.    c)  The 2005 PHA resulted in three (3) recommendations including; add a label and procedure to the Formaldehyde System Process Operating Manual regarding the Building 51 manifold, review a maintenance procedure which was added for cleaning D/P cells, and add warnings to the Formaldehyde System Process Operating Manual regarding closing an air supply valve before closing the tank valve.

Issued

Dec 20, 2016

Abate by

Jan 31, 2017

Penalty

Initial $0 · Current $400

Hazardous substances 1290

General-duty citation text

29 CFR 1910.119(l)(5): A change covered by this paragraph resulted in a change in the operating procedures or practices required by paragraph (f) of this section, and such procedures or practices were not updated accordingly:    On or about August 31, 2016, the employer did not update operating procedures or practices required by paragraph (f) of this section when Management of Change (MOC) procedures resulted in a changes to:    a)  On or about February 09, 2000, MOC 00.01 created a maintenance procedure which was contained in a Memo dated February 10, 2000 with Subject "Re:  Formaldehyde Tank Level Sensor - Procedure to Unplug Nozzle". The Maintenance Standard Safety Procedure (SSP), SSP 19.05, was updated with a note referencing the Memo procedure and requiring a maintenance supervisor of safety director to review the procedure. The Maintenance SSP operating procedure was not updated with the changes from the MOC regarding the cleaning of D/P cells.    b)  On or about September 18, 2000, MOC 00.02 created maintenance and operating procedures which were contained in a Memos both dated September 18, 2000 with Subjects "Re:  Cleaning Procedure for Formaldehyde Storage Tank" and "Re:  Overriding Control on Formaldehyde Distribution System Prior to Cleaning Procedure". The Maintenance SSP 19.05 and the Formaldehyde System Process Operating Manual were not updated with the changes from the MOC regarding the setup and cleaning procedures of the formaldehyde storage tank.

Issued

Dec 20, 2016

Abate by

Jan 31, 2017

Penalty

Initial $4,988 · Current $3,492 Reduced

Hazardous substances 1290

General-duty citation text

29 CFR 1910.119(f)(3): The employer did not annually certify that operating procedures were current and accurate:    a)  On or about August 31, 2016, the employer did not annually certify that the Maintenance Standard Safety Procedure, Formaldehyde System Process Operating Manual and Formaldehyde Unloading Procedure were current and accurate.

Issued

Dec 20, 2016

Abate by

Jan 31, 2017

Penalty

Initial $4,988 · Current $3,492 Reduced

Hazardous substances 1290

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not certify that they had evaluated compliance with the provisions of this section at least every three (3) years:    a)  On or about August 31, 2016, the employer did not certify that they had evaluated compliance with the provisions of this section at least every three years. The employer last conducted a compliance audit in January of 2012.

Issued

Dec 20, 2016

Abate by

Jan 31, 2017

Penalty

Initial $4,988 · Current $3,492 Reduced

Hazardous substances 1290

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 have been corrected:    On or about August 31, 2016, the employer did not document that deficiencies had been corrected when:    a)  The RMP/PSM Audit 2012 resulted in three (3) findings including; updating hard copies of the MOC procedure, complete required employee regulatory training, update training logs to remove references to "Propane System and Risk Management".    b)  The RMP/PSM Audit 2011 resulted in one (1) findings which was refresher training was due in 2010 but had not been completed.

Issued

Dec 20, 2016

Abate by

Jan 31, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1290

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) On or about August 31, 2016, the employer's process safety information pertaining to the equipment in the process did not include the safety systems including information such as design basis, design documents, operating parameters, and calibration/testing methods and frequency for the fire detection/suppression system.

Issued

Dec 20, 2016

Abate by

Jan 31, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1290

General-duty citation text

29 CFR 1910.119(n): The emergency action plan did not include procedures for handling small releases.  On or about August 31, 2016, the employer's emergency action plan did not include procedures employees could follow to distinguish between small releases/spill and large releases/spill of formaldehyde from the system.