OSHA Inspection: C. L. HAUTHAWAY & SONS CORP.

Issued

Oct 27, 2017

Abate by

Feb 3, 2020

Penalty

Initial $6,972 · Current $4,099 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i)(A): Information concerning the technology of the process did not include a block flow diagram or simplified process flow diagram:    (a) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, process safety information compiled for the manufacture of Product included a piping & instrumentation diagram as a substitute for a simplified process flow diagram.

Issued

Oct 27, 2017

Abate by

Feb 3, 2020

Penalty

Initial $6,972 · Current $4,099 Reduced

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) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, process safety information that had been developed for the manufacture of Product was not compiled.

Issued

Oct 27, 2017

Abate by

Feb 3, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(2)(i)(E): Information concerning the technology of the process did not include an evaluation of the consequences of deviations, including those affecting the safety and health of employees:    (a) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, process safety information compiled for the manufacture of Product did not include consequences of deviations from safe upper and lower operating limits.

Issued

Oct 27, 2017

Abate by

Feb 3, 2020

Penalty

Initial $9,760 · Current $5,738 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(C): Information pertaining to the equipment in process did not include an accurate electrical classification:    (a) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, process safety information compiled for the manufacture of Product included two electrical classification studies which were an incomplete and not fully accurate classification of hazardous (classified) locations where process equipment operated.

Issued

Oct 27, 2017

Abate by

Nov 27, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.305(b)(1)(ii): Unused openings in boxes, cabinets, or fittings were not effectively closed:    (a) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, a junction box on the opposite side of the wall of Reactor U-4 was missing two knockouts.

Issued

Oct 27, 2017

Abate by

Feb 3, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.307(c): Equipment, wiring methods, and installations of equipment in hazardous (classified) locations were not intrinsically safe, approved for the hazardous (classified) location, or safe for the hazardous (classified) location:    (a) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, electrical installations installed on the opposite side of the wall of Reactor U-4 were not intrinsically safe, approved for hazardous (classified) locations, or safe for the hazardous (classified) location.

Issued

Oct 27, 2017

Abate by

Feb 3, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.307(d): Conduits in hazardous (classified) locations were not threaded:    (a) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, the conduit for the electrical equipment installed on the opposite side of the wall of Reactor U-4 was not threaded.

Issued

Oct 27, 2017

Abate by

Feb 3, 2020

Penalty

Initial $9,760 · Current $5,738 Reduced

General-duty citation text

29 CFR 1910.119(f)(1): Written operating procedures providing clear instruction for conducting operations in a covered process safely and consistently with process safety information addressing all of  the elements listed in 29 CFR 1910.119(f)(1)(i) through 29 CFR 1910.119(f)(1)(iv) have not been developed and/or implemented:    (a) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, the written operating procedures associated with the manufacture of Product did not address emergency shutdown including under what conditions emergency shutdown is required and who is responsible for conducting emergency shutdown.    (b) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, the written operating procedures associated with the manufacture of Product did not address the consequences of deviation from operating limits.    (c) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, the written operating procedures associated with the manufacture of Product did not address steps required to correct or avoid deviation.    (d) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, the written operating procedures associated with the manufacture of Product did not address the properties of and the hazards presented by the chemicals used in the process.    (e) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, the written operating procedures (SA-002 - Personal Protective Equipment Section, SA-004 - Personal Protective Equipment Section, S-014 - Personal Protective Equipment Section, S-015 - Personal Protective Equipment Section, U-005 - Personal Protective Equipment Section, and U-015 - Personal Protective Equipment Section) associated with the manufacture of Product and related to personal protective equipment were not implemented. These operating procedures require the use of flame-resistant clothing (FRC) as a necessary precaution to protect operators during the manufacture of Product; however, the employer did not provide FRC or require, in practice, that it be used when operators conducted activities such as loading solid ingredients to heated flammable liquids through the manway of the reactor. This hazardous condition exposed employees to the hazard of flash fires.    (f) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, the written operating procedures associated with the manufacture of Product did not address control measures to be taken if physical contact or airborne exposure occurs.    (g) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, the written operating procedures associated with the manufacture of Product did not address fire protection systems and other safeguards credited in the 2015 HAZOP including the temperature indicator and recorder.

Issued

Oct 27, 2017

Abate by

Feb 3, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(v):     The process hazard analysis did not address facility siting:    (a) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, the hazards of siting the facility for the manufacture of Product with respect to the buildings, containers, or equipment associated with the other operations of the work site with the potential to affect a release of highly hazardous chemicals from the covered process have not been adequately addressed through process hazard analysis.

Issued

Oct 27, 2017

Abate by

Feb 3, 2020

Penalty

Initial $6,972 · Current $4,099 Reduced

General-duty citation text

29 CFR 1910.119(g)(3): A record which contained the identity of the employee, the date of training, and the means used to verify that the employee understood the training was not prepared:    (a) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, documentation identifying the employee trained, the date of the training, and the means used to verify that the employees understood the training was not complete for the reactor operators associated with the manufacture of Product.

Issued

Oct 27, 2017

Abate by

Feb 3, 2020

Penalty

Initial $9,760 · Current $5,738 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): Written procedures to maintain the on-going integrity of process equipment have not been established:    (a) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, written procedures have not been established for activities including inspection, testing, repair, correction of equipment deficiencies, and quality assurance to maintain the on-going integrity of process equipment, such as pressure vessels and storage tanks; piping systems such (including piping components such as valves); relief and vent systems and devices; emergency shutdown systems; controls (including monitoring devices and sensors, alarms, and interlocks); pumps and other safety-critical equipment, associated with the manufacture of Product.  This hazardous condition exposed employees to the hazard of fire/explosion.

Issued

Oct 27, 2017

Abate by

Feb 3, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(i): Inspections and tests were not performed on process equipment:    (a) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, Reactor U-4 has not been inspected.    (b) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, process piping associated with the manufacture of Product has not been hydrostatically tested.

Issued

Oct 27, 2017

Abate by

Feb 3, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(iv): Documentation of each inspection and test that had been performed on process equipment did not include a description of the inspection or test performed:    (a) Location - 638 Summer Street, Lynn, MA:    On or about 5/1/2017, documentation of a preventative maintenance procedure (Work Order Form ID# WKO-05396) performed on ground wires associated with the manufacture of Product did not fully describe the inspection or test performed.

Issued

Oct 27, 2017

Abate by

Feb 3, 2020

Penalty

Initial $34,858 · Current $20,498 Reduced

General-duty citation text

1910.119(d)(3)(ii): The employer did not document that equipment in the process complies with recognized and generally accepted good engineering practices:      (a) Location  638 Summer Street, Lynn, MA:      On or about 5/1/2017, the employer did not document that its organic coating process equipment, used in the manufacture (using flammable liquids) of Product, complied with recognized and generally accepted good engineering practice (RAGAGEP), such as NFPA 35, when it did not separate the organic coating process equipment associated with the manufacture of Product from other non-process areas within Building 1 (such as a warehouse for the storage of flammable liquids, a laboratory, offices, and the employee lunch room) by a 2-hour (minimum) fire resistance rated wall.  NFPA 35 (2016), Section 4.2.1., for example, and earlier editions of NFPA 35, require at least a 2-hour fire resistance rated wall between manufacturing operations and non-process areas housed in the same building.  The walls separating the process area from non-process areas in Building 1 lost their 2-hour (minimum) fire resistance rating due to various penetrations therein and wall material degradation. This hazardous condition exposed employees to the hazard of fire/explosion.      (b) Location  638 Summer Street, Lynn, MA:      On or about 5/1/2017, the employer did not document that its organic coating process equipment, used in the manufacture (using flammable liquids) of Product, complied with RAGAGEP, such as NFPA 35, when it located its process equipment in a building with a basement.  NFPA 35 (2016), Section 5.1.2, for example, and earlier editions of NFPA 35, preclude equipment for the manufacture of organic coatings using flammable liquids to be located in buildings with basements.  This hazardous condition exposed employees to the hazard of fire/explosion.      (c) Location  638 Summer Street, Lynn, MA:      On or about 5/1/2017, the employer did not document that its organic coating process equipment, used in the manufacture (using flammable liquids) of Product, complied with RAGAGEP, such as NFPA 35, when it used pumps to supply flammable liquids from storage to the organic coating manufacturing process of Product and did not provide emergency shutdown switches, in  addition to the Deadman switches on the individual pumps, such that all the pumps could be shut down at once to stop the flow of such liquids in the event of fire and which would feed the fire. NFPA 35 (2016), Section 6.1.1.2., for example, and earlier editions of NFPA 35, require pumps supplying solvents from storage to equipment for the manufacture of organic coatings using  flammable liquids to be provided with emergency switches to shut down all the pumps to stop the flow of liquids to prevent additional fuel from being added to any fire. This hazardous condition exposed employees to the hazard of fire/explosion.      C. L. Hauthaway & Sons Corp. was previously cited for a violation of this Occupational Safety and Health Standard 29 CFR 1910.119(d)(3)(ii), which was contained in OSHA inspection number 953707, citation number 2, item number 2 and was affirmed as a final order on 4/24/2014, with respect to a workplace located at 638 Summer Street, Lynn, MA, 01905.