OSHA Inspection: BRENNTAG SOUTHWEST

Issued

2018-05-14 00:00:00

Abate by

2018-06-01 00:00:00

Penalty

Initial $10477.00 · Current $6286.00 Reduced

General-duty citation text

29 CFR 1910.119(g)(2): The employer did not provide refresher training at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process:      On or about November 14, 2017 where the employer did not provide refresher training at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process.

Issued

2018-05-14 00:00:00

Abate by

2018-06-01 00:00:00

Penalty

Initial $10477.00 · Current $1000.00 Reduced

General-duty citation text

29 CFR 1910.119(i)(1): The employer did not perform a pre-startup safety review for new facilities and for modified facilities when the modification was significant enough to require a change in the process safety information.      On or about November 14, 2017, and at times prior thereto, where the employer did not perform a pre-startup safety review for modified facilities when the modification was significant enough to require a change in the process safety information, exposing employees to inhalation and contact hazards with chlorine.

Issued

2018-05-14 00:00:00

Abate by

2018-06-01 00:00:00

Penalty

Initial $10477.00 · Current $10477.00

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not implement written procedures to maintain the on-going integrity of process equipment      On or about November 14, 2017, where the employer's mechanical integrity program did not establish and implement written procedures to maintain the integrity of process equipment in the chlorine process area,  did not implement their mechanical integrity program for process equipment including, but not limited to the following:      a)      ET201: Expansion Chamber   b)      ET201: Pressure relief disk   c)      Rail Car Hoses H219 & H220   d)      I-203 (Interlock)  e)      Main PLC  f)       Unit Emergency shutdowns      The employer did not institute a mechanical integrity program which considered items such as, but not limited to:  1. establishing a critical equipment list in accordance with section 9.4 of their mechanical integrity program;  2. establishing frequency of inspection and testing for process equipment identified in their program;  3. establishing protocols for inspection and testing of process equipment;  4. determining the consensus standards to be used for inspection and testing of process equipment.

Issued

2018-05-14 00:00:00

Abate by

2018-06-01 00:00:00

Penalty

Initial $10477.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:    On or about November 14, 2017, and at times prior thereto, the employer did not perform inspection and tests on process equipment to maintain its on-going mechanical integrity, in the chlorine process area, for equipment including but not limited to:    a)   ET201: Expansion Chamber   b)   ET202: Expansion chamber  c)   ET203: Expansion Chamber  d)   ET204: Expansion Chamber  e)   ET201: Pressure relief disk   f)    ET202: Pressure relief disk  g)   ET203: Pressure relief disk  h)   ET204: Pressure relief disk  i)    Pipeline 1 CL-201-CS1 to 2-CL-201-CS1 injection into Powell Unit   j)    Pipeline 1 CL-219-GCS1   k)   Rail Car Hoses H219 & H220   l)    I-203 (Interlock)  m)  I-206 (Interlock)  n)   I-208 (Interlock)  o)   AutoMax Valve  p)   Main PLC  q)   Unit Emergency shutdowns

Issued

2018-05-14 00:00:00

Abate by

2018-06-01 00:00:00

Penalty

Initial $10477.00 · Current $6286.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The employer did not ensure that the frequency of inspections and tests of process equipment was consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.    On or about November 14, 2017 the employer did not ensure that frequency of inspection and testing of equipment in the process complied with recognized and generally accepted good engineering practices {RAGAGEP}, such as, but limited to, Chlorine Institute Pamphlet 85, Appendix 2, Piping Systems and Components, and American Petroleum Institute 570 (2018), Section 6, Interval/Frequency and Extent of Inspection for piping inspection frequency for the following equipment:    a)  Pipeline 1 CL-201-CS1  to 2-CL-201-CS1 injection into Powell Unit  b)   Pipeline 1 CL-219-GCS1

Issued

2018-05-14 00:00:00

Abate by

2018-06-01 00:00:00

Penalty

Initial $10477.00 · Current $10477.00

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 November 14, 2017 and at times prior thereto, where the employer did not update procedures or practices when a change covered by this paragraph resulted in a change in the operating procedures or practices as required by paragraph (f), exposing employees to inhalation and contact hazards with chlorine.

Issued

2018-05-14 00:00:00

Abate by

2018-06-01 00:00:00

Penalty

Initial $10477.00 · Current $1000.00 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not certify that they had evaluated compliance with the provisions of 29 CFR 1910.119 at least every three years to verify that the procedures and practices developed under this standard were adequate and were being followed:      On or about November 15, 2017 and at times prior thereto, where employer did not ensure that process safety management compliance audits are conducted for the Chlorine system every three years as required by the standard, exposing employees to the hazards associated with uncontrolled releases of chlorine liquid and/or vapors into the atmosphere.

Issued

2018-05-14 00:00:00

Abate by

2018-06-01 00:00:00

Penalty

Initial $0.00 · Current $0.00

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.    On or about November 14, 2017, and at times prior thereto, where the employer did not ensure that piping and instrumentation diagrams were accurate and represent equipment that was existing and was part of the process.

Issued

2018-05-14 00:00:00

Abate by

2018-06-01 00:00:00

Penalty

Initial $840.00 · Current $840.00

General-duty citation text

29 CFR 1910.119(f)(3): The employer did not review operating procedures as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities.  The employer shall certify annually that these operating procedures are current and accurate.    On or about November 14, 2017 and at times prior thereto, where the employer did not review operating procedures as often as necessary, and did not certify annually that the operating procedures were current and accurate for the Chlorine system.