OSHA Inspection: GIVAUDAN FLAVORS CORPORATION

Issued

Jan 11, 2018

Abate by

May 31, 2018

Penalty

Initial $12,934 · Current $12,000 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) Building 2, vanilla area.    The employer did not compile process safety information (PSI) that was specific to safe operating limits for temperature and pressure for vanilla box extractors 40 and 41.    Violation occurred on or about 7/13/17.      b)  Building 2, oleo area.     The employer did not compile process safety information (PSI) that was specific to safe operating limits for temperature and pressure for spice box extractor 69.    Violation occurred on or about 7/13/17.

Issued

Jan 11, 2018

Abate by

Feb 26, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): Information pertaining to equipment in the process did not include relief system design and design basis:    a)  Building 2, vanilla area    The employer did not compile PSI that was specific to design and design basis for pressure safety valves on vanilla box extractors 40-42 and concentrators 45-47.    Violation occurred on or about 7/13/17.

Issued

Jan 11, 2018

Abate by

May 31, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F): Information pertaining to equipment in the process did not include design codes and standards employed:    a) Building 2, oleo  area    The employer did not compile PSI that was specific to design codes and standards employed for spice box extractor 69.    Violation occurred on or about 7/13/17.    b) Building 2, vanilla area    The employer did not compile PSI that was specific to design codes and standards employed for vanilla box extractors 40 and 41.    Violation occurred on or about 7/13/17.    c)  Building 2, oleo, vanilla and large stills areas    The employer did not compile PSI that was specific to design codes and standards employed for emergency shutdown systems (E stops) and safety interlocks.    Violation occurred on or about 7/13/17.

Issued

Jan 11, 2018

Abate by

Dec 31, 2018

Penalty

Initial $12,934 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complied with recognized and generally accepted good engineering practices (RAGAGEP):    a)  Building 2 oleo area    The employer did not document that spice box extractor 69 marking was visible pursuant to RAGAGEP ASME Boiler and Pressure Vessel Code (2007) Section VIII Division 1, Subsection A, Part UG-116.         Violation occurred on or about 7/13/17.    b)  Building 2      The employer did not compile PSI that documented that all pressure relief valves from extractors, concentrators and large stills vented to a safe location pursuant to RAGAGEP ASME Boiler and Pressure Vessel Code (2007) Section VIII Division 1 Subsection A, Part UG-135(f).  The April 2013 Process Hazard Analysis nodes 2.2.5, 3.2.1, 4.4.1, 5.2.2 and 7.14 indicated that overpressure could develop in process vessels.  Pressure safety valves vented onto the roof, where motors to the HVAC system could serve as ignition sources.      Violation occurred on or about 7/13/17.

Issued

Jan 11, 2018

Abate by

May 31, 2018

Penalty

Initial $9,239 · Current $12,000

General-duty citation text

29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not address the consequences of failure of engineering and administrative controls:    a) Building 2    The April 2013 Process Hazard Analysis did not address the consequences of failure of the lower explosive level (LEL) monitors, local exhaust ventilation and safety interlocks.    Violation occurred on or about 7/13/17.

Issued

Jan 11, 2018

Abate by

May 31, 2018

Penalty

Initial $12,934 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting.    a) Establishment      The April 2013 Process Hazard Analysis did not evaluate whether adjacent equipment or facilities could withstand overpressure by potential explosions or flame impingement.      Violation occurred on or about 7/13/17.

Issued

Jan 11, 2018

Abate by

Feb 26, 2018

Penalty

Initial $12,934 · Current $8,000 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 2, large stills    The written operating procedures developed by the employer for Operating a Pot, Operating a Splitter, Operating a Reflux Condenser and Emptying a Receiver did not provide steps for each operating phase, operating limits, safety and health considerations or safety systems and their functions.    Violation occurred on or about 7/13/17.

Issued

Jan 11, 2018

Abate by

Feb 26, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(i)(D): The employer did not develop and implement written operating procedures that provide clear instructions for emergency shutdown, including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner:    a) Building 2, oleo and vanilla areas    The employer's written operating procedures did not address emergency shutdown including the conditions under which emergency shutdown is required, the assignment of shutdown responsibility and the use of emergency stop buttons.    Violation occurred on or about 7/13/17.

Issued

Jan 11, 2018

Abate by

Feb 26, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(i)(G): The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and did not address the startup following a turnaround, or after an emergency shutdown:    a)  Building 2, oleo, vanilla and large stills areas    The employer had no written operating procedures for start-up after an emergency shutdown.    Violation occurred on or about 7/13/17.

Issued

Jan 11, 2018

Abate by

Feb 26, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(iv): The employer's written operating procedures did not address safety systems and their functions.    a)  Building 2, oleo, vanilla and large stills areas    The employer's written operating procedures did not address Lower Explosive Level (LEL), temperature and level sensors and alarms.    Violation occurred on or about 7/13/17.

Issued

Jan 11, 2018

Abate by

May 31, 2018

Penalty

Initial $12,934 · Current $8,000 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 2 oleo, vanilla and large stills areas    The employer did not establish and implement written mechanical integrity procedures for inspecting, testing and preventive maintenance (ITPM) of pressure vessels including conical extractors, heat exchangers, falling film evaporators, concentrators, box extractors and stills.     Violation occurred on or about 7/13/17.    b)  Building 2 oleo, vanilla and large stills areas    The employer did not establish and implement written mechanical integrity procedures for ITPM of process piping systems that conveyed flammable solvents (ethanol, acetone, ethyl acetate and heptane).  ITPM relied on the experience and judgment of mechanics following task lists rather than stepwise written procedures.      Violation occurred on or about 7/13/17.    c)  Building 2 oleo, vanilla and large stills areas    The employer did not establish and implement written mechanical integrity procedures for ITPM of emergency shutdown systems (E stops).      Violation occurred on or about 7/13/17.    d)  Building 2 oleo, vanilla and large stills areas    The employer did not establish and implement written mechanical integrity procedures for ITPM of safety interlocks.  These interlocks opened or closed automatic valves in steam lines, charge lines or drain lines in response to signals from temperature, level and flow sensors in process equipment.      Violation occurred on or about 7/13/17.

Issued

Jan 11, 2018

Abate by

May 31, 2018

Penalty

Initial $12,934 · Current $12,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:     a)  Building 2 oleo, vanilla and large stills areas     The employer did not inspect or test emergency shutoff systems (E stops) that shut down pneumatic equipment throughout the plant.        Violation occurred on or about 7/13/17.        b)  Building 2, oleo, vanilla and large stills areas.      The employer did not inspect or test portable pumps used to transfer flammable liquids into process piping and equipment.      Violation occurred on or about 7/13/17.      c)  Building 2, oleo, vanilla and large stills areas      The employer did not inspect or test process piping used to convey flammable liquids.       Violation occurred on or about 7/13/17.

Issued

Jan 11, 2018

Abate by

Nov 30, 2018

Penalty

Initial $12,934 · Current $12,000 Reduced

General-duty citation text

29 CFR1910.119(j)(4)(ii)  Inspections and testing procedures performed on process equipment to maintain its mechanical integrity did not follow recognized and generally accepted good engineering practices (RAGAGEP):    a)  Building 2 oleo, vanilla and large stills areas.      Regarding the testing of pressure safety valves, employer did not require documentation of observations (physical condition, material deposits, plugging, etc.), actual pressure readings and measurements in accordance with RAGAGEP API RP 576, Third edition, 2009, Inspection of Pressure Relieving Devices, Sections 6.2.6, 6.2.9 and 6.2.10.      Violation occurred on or about 7/13/17.         b)  Building 2 oleo, vanilla and large stills areas.      Regarding the conical extractors, concentrators, box extractors and stills, the employer's  maintenance staff did not possess the required credentials nor did they conduct inspection and testing in accordance with RAGAGEP API 510, Tenth edition, 2014, Pressure Vessel Inspection Code  In-service Inspection, Rating, Repair and Alteration, Sections 3.1.5 and Annex B.        Violation occurred on or about 7/13/17.      c)  Building 2 oleo, vanilla and large stills areas      Regarding the solvent holding tanks, aging tanks and mixing/blending tanks, employer's maintenance staff did not possess the required credentials nor conduct examinations in accordance with RAGAGEP  STI SP001 Standard for Inspection of Aboveground Storage Tanks (2011).        Violation occurred on or about 7/13/17.

Issued

Jan 11, 2018

Abate by

Feb 26, 2018

Penalty

Initial $12,934 · Current $12,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment was not consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience:    a)  Building 2 - oleo area    Instrumentation on solvent holding tank A was not inspected and tested by its required due dates  Masoneilan 35-3512 temperature control valve HLC 450 was last tested 4/25/16.  Annual re-inspection and testing was required by 4/25/17 based on employer's prior experience.        Violation occurred on or about 7/13/17.    b)  Building 2 - oleo area    Instrumentation on solvent holding tank A was not inspected and tested by its required due date.  JMS Type J thermocouple HLC239 was last tested 4/25/16.  Annual re-inspection and testing was required by 4/25/17 based on employer's prior experience.      Violation occurred on or about 7/13/17.    c)  Building 2 - oleo area    Instrumentation on solvent holding tank A was not inspected and tested by its required due date.  Fisher Control Y600 pressure control valve 12726444 was last tested 4/25/16.  Annual re-inspection and testing was required by 4/25/17 based on employer's prior experience.      Violation occurred on or about 7/13/17.    d)  Building 2  - large stills    Instrumentation on large still 24 was not inspected and tested by the due date.  Masoneilan 35-35212 flow control valve, JMS type J thermocouples HLC 39 and HLC 40, Ametek DT-8320 temperature indicator HLC 35, Yokagawa YF102 flow transmitter 231213013, Rosemount 3051 pressure transmitter 7742450, Jo-Bell MT-1 high level switch and Fisher Controls Y690 pressure control valve MY01322375 were last inspected and tested 6/29/16.  Annual re-inspection and testing was required by 6/29/17 based on employer's prior experience.      Violation occurred on or about 7/13/17.

Issued

Jan 11, 2018

Abate by

Oct 31, 2018

Penalty

Initial $12,934 · Current $12,000 Reduced

General-duty citation text

29 CFR 1910.132(d)(1): The employer did not assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE):      a) Building 2    The employer's hazard assessment did not take into account employee exposures to flash fire hazards when transferring flammable liquids, tending and operating process equipment.    Violation occurred on or about 7/13/17.