OSHA Inspection: MGPI PROCESSING INC.

Issued

Apr 19, 2017

Abate by

Sep 6, 2017

Penalty

Initial $12,675 · Current $10,901 Reduced

General-duty citation text

29 CFR 1910.36(b)(2): More than two exit routes were not available in the workplace where the number of employees, the size of the building, its occupancy, or the arrangement of the workplace was such that all employees would not be able to evacuate safely during an emergency:    On or about October 21, 2016 MGPI Specialty Starch operators working inside the control room of the Specialty Starch building were exposed to toxic chemical vapors during an emergency evacuation through the only exit door inside the control room section of the building.  The employee(s) exited through the only exit door that had a storage tank venting toxic chemical vapors due to incompatible chemicals Sodium Hypochlorite and Sulfuric Acid being mixed.

Issued

Apr 19, 2017

Abate by

Sep 6, 2017

Penalty

Initial $12,675 · Current $0 Reduced

General-duty citation text

29 CFR 1910.1200(h)(3)(iii): Employee training did not include the measures employees can take to protect themselves from chemical hazards, including specific procedures the employer had implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures and personal protective equipment to be used:    On or about October 21, 2016, a Harcros Chemical sulfuric acid tanker #610 was unloading sulfuric acid into the Specialty Starch buildings tank farm Sodium Hypochlorite tank.  The Harcros Chemical tanker #610 transfer hose was connected to the wrong transfer piping portal at the unloading station.  The Harcros Chemical driver started unloading sulfuric acid from Harcros tanker #610 into the Sodium Hydrochloride tank resulting in a chemical reaction that caused the toxic hazardous mixture to vent out into the atmosphere engulfing the Specialty Starch building and parts of Atchison, Kansas.  The Specialty Starch operator did not verify that the sulfuric acid transfer hose was connected to the sulfuric acid piping portal, did not open the valve after the driver was ready to unload sulfuric acid, and did not confirm the sulfuric acid was being transferred to the tank by observing the level on the tank. Employees lacked the required hazard communication training to following the standard operating procedures to unload sulfuric acid, thus exposing employee(s) to inhalation of toxic hazardous gases.

Issued

Apr 19, 2017

Abate by

Sep 6, 2017

Penalty

Initial $12,675 · Current $10,901 Reduced

General-duty citation text

29 CFR 1910.119(d): The employer did not complete a compilation of written process safety information pertaining to the equipment in the process:    (a) Employee(s) working inside the Specialty Starch control room located at 1200 Gasoline Alley were exposed to toxic vapors due to no design codes or standards being used for the pressurized control room.     (b)   At the establishment the employer had not established safe upper and lower limits for temperature and pressures for the propylene oxide transfer hose that was connected to the piping portal at the unloading station at the Specialty Starch building.    (c)   No retirement thickness measurements were included in the process safety information for phosphorus oxychloride or propylene oxide piping lines at the Specialty Starch building.    (d)  No manufacturer design pressures or temperatures were included in the process safety information for the Propylene Oxide day tank.      Employees were exposed to release of volatile organic compounds (VOC)s to atmosphere that historically result in explosion, fire, and health hazards leading to injury and death to employees in the workplace.

Issued

Apr 19, 2017

Abate by

Sep 6, 2017

Penalty

Initial $5,432 · Current $4,925 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process:    At the Specialty Starch building, the employer had not verified that all P&ID's were up to date and accurate for use by Specialty Starch employee(s) and contractors for the process hazard analysis, line breaks, equipment/piping replacement/repairs, and etc., the following was noted:      (a) a propylene oxide transfer hose was attached to the propylene oxide piping portal during the walk around, but not drawn on the p&id drawing MBP&ID.13      (b) during the walk around a pipe reducer was observed between check valve 268 and propylene oxide transfer pump M-713,  the piping section was reduced from 3 inches to 1 inch and was not drawn on the p&id drawing MBP&ID.13      (c) a coupler was observed on the 1 inch propylene oxide pipe line from the propylene oxide day tank to ball valve 31, but drawn on the p&id drawing MBP&ID.06      (d) an union was observed between pneumatic ball valve SV1220 and ball valve 32, but not drawn on p&id drawing MBP&ID.06      (e) an union was observed between ball valve 32 and check valve 33, but not drawn on p&id drawing MBP&ID.06      (f) an union was observed between pneumatic ball valve SV1221 and ball valve 66, but not drawn on p&id drawing MBP&ID.07      (g) an union was observed between ball valve 66 and check valve 65, but not drawn on p&id drawing MBP&ID.07      (h) an union was observed between pneumatic ball valve SV1222 and ball valve 107, but not drawn on p&id drawing MBP&ID.08      (i) an union was observed between ball valve 107 and check valve 106, but not drawn on p&id drawing MBP&ID.08    Employees were exposed to release of volatile organic compounds (VOC)s to atmosphere that historically result in explosion, fire, and health hazards leading to injury and death to employees in the workplace.

Issued

Apr 19, 2017

Abate by

Sep 6, 2017

Penalty

Initial $12,675 · Current $10,901 Reduced

General-duty citation text

29 CFR 1910.119(e)(1): 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:     At the facility the employer did not perform an adequate process hazard analysis for the propylene oxide and phosphorus oxychloride processes.  The following hazards were not addressed in the employer's hazard analysis:    (a)  The employer did not perform a process hazard analysis addressing toxic or flammable vapors entering the control room through the pressurized air handling equipment.    (b)  The employer did not perform a process hazard analysis at the unloading station of the Specialty Starch building where a highly hazardous chemical was transferred to the wrong chemical storage tank by a delivery driver.    (c)  The employer did not perform a process hazard analysis addressing the location of each piping portal for off loading highly hazardous chemicals at the Specialty Starch building.      Employee(s)  were exposed to release of extremely flammable / toxic vapors to atmosphere that historically resulted in fire, explosion, and health hazards leading to injury and death to persons in the workplace.

Issued

Apr 19, 2017

Abate by

Sep 6, 2017

Penalty

Initial $12,675 · Current $0 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:     The employer failed to adequately address fire / explosion hazards related to the facility siting of occupied structures including, but not limited to the control room inside the Specialty Starch building.      Employees were exposed to release of volatile organic compounds (VOC)s to atmosphere that historically result in explosion, fire, and health hazards leading to injury and death to employees in the workplace.

Issued

Apr 19, 2017

Abate by

Sep 6, 2017

Penalty

Initial $9,054 · Current $7,786 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 the safety information and which address the elements listed in 29 CFR 1910.119(f)(1)(i) through (f)(1)(v):     At the Specialty Starch building a written standard operating procedure had not been developed and implemented for addressing operator shift changes.    Employees were exposed to release of volatile organic compounds (VOC)s to atmosphere that historically result in explosion, fire, and health hazards leading to injury and death to employees in the workplace.

Issued

Apr 19, 2017

Abate by

Sep 6, 2017

Penalty

Initial $12,675 · Current $10,901 Reduced

General-duty citation text

29 CFR 1910.119(g)(1)(i): The employer did not train each employee in an overview of the process:     (a) At the establishment the employer had not provided effective training over the standard operating procedures in that during the toxic chemical vapor leak on October 21, 2016, operators left the control room unoccupied during an emergency evacuation and did not shut down the processes.    (b) At the establishment the employer had not provided training to Specialty Starch operators to shut down the air handling equipment that was pressurizing the control room.  Toxic vapors entered the control room on October 21, 2016 through the pressurized equipment causing the Specialty Starch operators to evacuate into the toxic vapor cloud outside the building.     Employees were exposed to release of volatile organic compounds (VOC)s to atmosphere that historically result in explosion, fire, and health hazards leading to injury and death to employees in the workplace.

Issued

Apr 19, 2017

Penalty

Initial $12,675 · Current $10,901 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on the following process equipment and piping:    a)  Propylene Oxide Bulk tank     b)  Propylene Oxide Day tank    c)  Propylene Oxide piping inspections    Employees were exposed to release of volatile organic compounds (VOC)s to atmosphere that historically result in explosion, fire, and health hazards leading to injury and death to employees in the workplace.

Issued

Apr 19, 2017

Abate by

Sep 6, 2017

Penalty

Initial $9,054 · Current $7,786 Reduced

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:    The level probe inside the propylene oxide bulk tank has been disconnected, thus rendering the safety systems to be inoperable during the off loading of propylene oxide from a delivery tanker.    Employees were exposed to release of volatile organic compounds (VOC)s to atmosphere that historically result in explosion, fire, and health hazards leading to injury and death to employees in the workplace.