OSHA Inspection: KUEHNE CHEMICAL CO., INC.

Issued

Mar 22, 2017

Abate by

May 3, 2017

Penalty

Initial $6,519 · Current $2,136 Reduced

General-duty citation text

29 CFR 1910.23(b)(2): Ladder rungs, steps, and cleats are spaced not less than 10 inches (25 cm) and not more than 14 inches (36 cm) apart, as measured between the centerlines of the rungs, cleats, and steps, except specified in 1910.23(b)(2)(i) and 1910.23(b)(2)(ii):      a) Unloading station #6 Cat Walk    The fixed ladder rungs were spaced 15.5 inches apart exposing workers to fall hazards of approximately 6 feet to the work platform below.      Violation was observed on or about 03/06/2017.

Issued

Mar 22, 2017

Abate by

Nov 3, 2017

Penalty

Initial $11,408 · Current $7,200 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address the hazards related to facility siting:     a) Railcar Area    The employer's 2015 PHA did not address the hazards associated with positioning Chlorine railcars so that they extend beyond protective concrete barriers, exposing the railcars to impact from vehicular traffic.     b)  Ton Container Storage Area    The employer's 2015 PHA failed to address hazards associated with vehicles such as tractor-trailers  striking 1-ton chlorine containers where existing protection using unsecured concrete curbing is insufficient.      c) Brine to Bleach Building    The employer's 2015 PHA failed to address the impact of a chlorine release from process areas on the Brine to Bleach Building where the positive pressure HVAC system's pressure differential indicators were malfunctioning.        Violations observed on or about 09/22/2016 through 03/06/2017.

Issued

Mar 22, 2017

Abate by

Aug 3, 2017

Penalty

Initial $11,408 · Current $7,200 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish or implement written procedures to maintain the on-going integrity of process equipment:    a) Chlorine Process    The employer failed to implement procedures to ensure that ultrasonic examination (UT) is repeated on piping and process equipment at the same Thickness Measurement Locations (TMLs).  ISO-1003-20 the east expansion chamber readings for an associated TML in 2011, 2013 and 2015 were 446, 446, 226, respectively.     b) Chlorine Process    The employer failed to implement procedures to ensure that ultrasonic examination (UT) is repeated on piping and process equipment at the same Thickness Measurement Locations (TMLs).  ISO-1003-20 the east expansion chamber readings for an associated TML in 2011, 2013 and 2015 were 191, 517 and 191, respectively.     c) Chlorine Process    The employer failed to implement procedures to ensure that ultrasonic examination (UT) is repeated on piping and process equipment at the same Thickness Measurement Locations (TMLs).  ISO 1003-32 TML C of the 3/4" CL2 line indicates readings of 215, 204 and 237 for 2011, 2013 and 2015, respectively.    d) Chlorine Process    The employer failed to implement procedures to ensure that ultrasonic examination (UT) is repeated on piping and process equipment at the same Thickness Measurement Locations (TMLs). ISO-1003-40 TML G of the 3/4" CL2 line indicates readings of 176, 186, 241 for 2011, 2013 and 2015, respectively.     e) Chlorine Process    The employer failed to inspect process piping identified in ISO-1002-00. Ultrasonic examination (UT) was performed at TMLs "F", "G" and "H" in 2015 but were omitted in 2013.  In 2011 UT was performed at TML "G" with no readings documented for TMLs "F" and "H".    f) Chlorine Process    The employer failed to inspect process piping identified in ISO-1002-01.  Ultrasonic examination (UT) was performed at TML "G" in 2013, however no readings were taken in 2011 and 2015.      Violation occurred on or about 9/22/2016 - 03/06/2017.

Issued

Mar 22, 2017

Abate by

Nov 3, 2017

Penalty

Initial $11,408 · Current $7,200 Reduced

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (as defined by the process safety information in 29 CFR 119(d)) before further use or in a safe and timely manner:    a) Chlorine Process    The employer failed to correct recommendations identified in the 2015 TAI Report for Chlorine System Piping & Vessels to include but are not limited to paint failures observed in ISO-1001-10 East KO Pot, ISO-1002-00 KO pots and associated piping, ISO 1002-11 paint failure along complete lines, ISO-1001-12 coating failure upper half of vessel, ISO-1001-11 vessel paint failure with surface rust.      Violation occurred on or about 09/22/2016 - 03/06/2017.

Issued

Mar 22, 2017

Abate by

Aug 3, 2017

Penalty

Initial $11,408 · Current $7,200 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not establish written procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process:     a) Brine to Bleach Building    The employer failed to implement MOC procedures to evaluate how the existing chlorine process, including potential chlorine release scenarios, would impact employees working in the Brine to Bleach (B to B) Building when that building was constructed adjacent to the chlorine process area.      c) Chlorine Process    The employer failed to implement MOC procedures when marking TMLs "C" and "C1" on Piping Isometric ISO-1004-00 as OMIT.  Readings were not taken at the "C" TML on the Blow Down Line in 2011 and 2013.  Readings were not taken at the "C1" TML on Lines 1,2,3 and 4 in 2011, 2013 and 2015.        Violation occurred on or about 03/06/2017.

Issued

Mar 22, 2017

Abate by

May 3, 2017

Penalty

Initial $11,408 · Current $7,200 Reduced

General-duty citation text

29 CFR 1910.119(n):  The employer failed to shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38:    a) Brine to Bleach Building    The employer's Emergency Response Program - EHS (Chlorine) does not include the steps employees must take in order to shelter-in-place within the facility to include but not limited to requirements involving the continued operation or shut down of the building positive pressure system in the case of a chlorine release.      Violation observed on or about 03/06/2017.