OSHA Inspection: R. STRESAU LABORATORY, INC.

Issued

Jun 4, 2018

Abate by

Mar 28, 2019

Penalty

Initial $9,959 · Current $6,970 Reduced

General-duty citation text

29 CFR 1910.119(e)(1): The employer did not perform an initial process hazard analysis (hazard evaluation) on processes covered by 29 CFR 1910.119:    (a) Building 10 Explosive Preparation; The employer did not perform an initial process hazard analysis on the tasks involved in this building such as, but not limited to, operating the remote drying and metering station, and breakdown of bulk primary.    (b) Explosive Preparation; The employer did not perform an initial process hazard analysis on the hazards of energetic waste such as, but not limited to, the burning of energetic waste in the Thermal Treatment Unit (TTU), burning energetic waste in burn troughs, burning scrap detonators in the TTU, collection and storage of energetic waste, and handling and cleanup of overturned powder carriers.

Issued

Jun 4, 2018

Abate by

Mar 28, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(iii): The process hazard analysis did not address engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of potential hazards (i.e. acceptable detection methods might include process monitoring, control instrumentation with alarms, detection hardware, safety interlocks, etc.):      (a) PHA 17028 - Job B892; The PHA dated December 19, 2017 does not address the detection methods utilized to identify and warn employees of potential hazards, including but not limited to, improper grounding, humidity, friction, compression, and failure of ventilation when manufacturing energetic devices.     (b) PHA 17022- Job C107; The PHA dated January 10, 2018 does not address the detection methods utilized to identify and warn employees of potential hazards, including but not limited to, improper grounding, humidity, friction, compression, and failure of ventilation when manufacturing energetic devices.     (c) PHA 17023 - Job B857; The PHA dated January 17, 2018 does not address the detection methods utilized to identify and warn employees of potential hazards, including but not limited to, improper grounding, humidity, friction, compression, and failure of ventilation when manufacturing energetic devices.     (d) PHA 17025 - Job C112; The PHA dated January 17, 2018 does not address the detection methods utilized to identify and warn employees of potential hazards, including but not limited to, improper grounding, humidity, friction, compression, and failure of ventilation when manufacturing energetic devices.     (e) PHA 17026 - Job C105;The PHA dated January 29, 2018 does not address the detection methods utilized to identify and warn employees of potential hazards, including but not limited to, improper grounding, humidity, friction, compression, and failure of ventilation when manufacturing energetic devices.     (f) PHA 17029- Remote Drying Station; The PHA dated April 25, 2018 does not address the detection methods utilized to identify and warn employees of potential hazards, including but not limited to, improper grounding, humidity, friction, compression, and failure of ventilation when manufacturing energetic devices.

Issued

Jun 4, 2018

Abate by

Mar 28, 2019

Penalty

Initial $0 · Current $0

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) PHA 17028 - Job B892; The PHA dated December 19, 2017 does not address the consequences of failure of  engineering and administrative controls, including but not limited to, grounding, humidity control, and failure of ventilation when manufacturing energetic devices.     (b) PHA 17022- Job C107; The PHA dated January 10, 2018 does not address the consequences of failure of  engineering and administrative controls, including but not limited to, grounding, humidity control, and failure of ventilation when manufacturing energetic devices.      (c) PHA 17023 - Job B857; The PHA dated January 17, 2018 does not address the consequences of failure of  engineering and administrative controls, including but not limited to, grounding, humidity control, and failure of ventilation when manufacturing energetic devices.     (d) PHA 17025 - Job C112; The PHA dated January 17, 2018 does not address the consequences of failure of  engineering and administrative controls, including but not limited to, grounding, humidity control, and failure of ventilation when manufacturing energetic devices.     (e) PHA 17026 - Job C105;The PHA dated January 29, 2018 does not address the consequences of failure of  engineering and administrative controls, including but not limited to, grounding, humidity control, and failure of ventilation when manufacturing energetic devices.     (f) PHA 17029- Remote Drying Station; The PHA dated April 25, 2018 does not address the consequences of failure of  engineering and administrative controls, including but not limited to, grounding, humidity control, and failure of ventilation when manufacturing energetic devices.

Issued

Jun 4, 2018

Abate by

Mar 28, 2019

Penalty

Initial $0 · Current $0

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) PHA 17028 - Job B892; The PHA dated December 19, 2017 does not address the hazards related to facility siting per building and per room based on the explosives utilized, the quantity, and the tasks being performed when manufacturing energetic devices.       (b) PHA 17022- Job C107; The PHA dated January 10, 2018 does not address the hazards related to facility siting per building and per room based on the explosives utilized, the quantity, and the tasks being performed when manufacturing energetic devices.     (c) PHA 17023 - Job B857; The PHA dated January 17, 2018 does not address the hazards related to facility siting per building and per room based on the explosives utilized, the quantity, and the tasks being performed when manufacturing energetic devices.     (d) PHA 17025 - Job C112; The PHA dated January 17, 2018 does not address the hazards related to facility siting per building and per room based on the explosives utilized, the quantity, and the tasks being performed when manufacturing energetic devices.     (e) PHA 17026 - Job C105;The PHA dated January 29, 2018 does not address the hazards related to facility siting per building and per room based on the explosives utilized, the quantity, and the tasks being performed when manufacturing energetic devices.      (f) PHA 17029- Remote Drying Station; The PHA dated April 25, 2018 does not address the hazards related to facility siting per building and per room based on the explosives utilized, the quantity, and the tasks being performed when manufacturing energetic devices.

Issued

Jun 4, 2018

Abate by

Mar 28, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not address human factors:     (a) PHA 17028 - Job B892; The PHA dated December 19, 2017 does not address potential human factor hazards, including but not limited to, accidental dropping of energetic material, sources and reduction of static, compression, impact, and friction, when manufacturing energetic devices.     (b) PHA 17022- Job C107; The PHA dated January 10, 2018 does not address the human factor hazards, including but not limited to, accidental dropping of energetic material, sources and reduction of static, compression, impact, and friction, when manufacturing energetic devices.     (c) PHA 17023 - Job B857; The PHA dated January 17, 2018 does not address the human factor hazards, including but not limited to, accidental dropping of energetic material, sources and reduction of static, compression, impact, and friction, when manufacturing energetic devices.     (d) PHA 17025 - Job C112; The PHA dated January 17, 2018 does not address the human factor hazards, including but not limited to, accidental dropping of energetic material, sources and reduction of static, compression, impact, and friction, when manufacturing energetic devices.     (e) PHA 17026 - Job C105; The PHA dated January 29, 2018 does not address the human factor hazards, including but not limited to, accidental dropping of energetic material, sources and reduction of static, compression, impact, and friction, when manufacturing energetic devices.    (f) PHA 17029- Remote Drying Station; The PHA dated April 25, 2018 does not address the human factor hazards, including but not limited to, accidental dropping of energetic material, sources and reduction of static, compression, impact, and friction, when manufacturing energetic devices.

Issued

Jun 4, 2018

Abate by

Mar 28, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to assure that the recommendations of process hazard analyses (PHAs) were resolved in a timely manner and that the resolutions were documented:    a) PHA 17028 - Job B892; The PHA dated December 19, 2017 indicates an action item of performing an air quality check; no documentation or system was identified to ensure recommendations from the PHAs were prioritized and tracked to completion with resolutions documented.

Issued

Jun 4, 2018

Abate by

Jun 3, 2019

Penalty

Initial $9,959 · Current $6,970 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(D): The employer did not develop and implement written operating procedures that provided clear instructions for 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) GWI-EXP-2 Burning Energetic Waste; The operating procedure does not include specific conditions under which emergency shutdown is required specific to the operational tasks.     (b) GWI-EXP-3 Burning Energetic Waste in Burn Troughs; The operating procedure does not include specific conditions under which emergency shutdown is required specific to the operational tasks.     (c) GWI-EXP-4- Burning Scrap Detonators; The operating procedure does not include specific conditions under which emergency shutdown is required specific to the operational tasks.      (d) GWI-EXP- 10- Breakdown of Bulk Primary; The operating procedure does not include specific conditions under which emergency shutdown is required specific to the operational tasks.     (e) GWI-EXP-6- Operating the Remote Drying and Metering Station; The operating procedure does not include specific conditions under which emergency shutdown is required specific to the operational tasks.     (f) PCP- 645- Stab Detonator- Automated Line; The operating procedure does not include specific conditions under which emergency shutdown is required specific to the operational tasks.     (g) GWI-SAF-24- Blasting Cap Shearing Operation; The operating procedure does not include specific conditions under which emergency shutdown is required specific to the operational tasks.     (h) PCP 569- M-6 Blasting Cap ;The operating procedure does not include specific conditions under which emergency shutdown is required specific to the operational tasks.     (i) PCP 270- Body Loaded; The operating procedure does not include specific conditions under which emergency shutdown is required specific to the operational tasks.

Issued

Jun 4, 2018

Abate by

Jun 3, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(ii): The employer's written operating procedures did not address the requirements for the operating limits listed in 29 CFR 1910.119(f)(1)(ii)(A) and (B):     (a) GWI-EXP-2 Burning Energetic Waste; The operating procedure does not include the consequences of deviating from the safe operating limits,  and clear steps to avoid or correct deviations when working with energetic materials.     (b) GWI-EXP-3 Burning Energetic Waste in Burn Troughs; The operating procedure does not include the consequences of deviating from the safe operating limits,  and clear steps to avoid or correct deviations when working with energetic materials.      (c) GWI-EXP-4- Burning Scrap Detonators; The operating procedure does not include the consequences of deviating from the safe operating limits,  and clear steps to avoid or correct deviations when working with energetic materials.        (d) GWI-EXP- 10- Breakdown of Bulk Primary; The operating procedure does not include the consequences of deviating from the safe operating limits,  and clear steps to avoid or correct deviations when working with energetic materials.     (e) GWI-EXP-6- Operating the Remote Drying and Metering Station; The operating procedure does not include the consequences of deviating from the safe operating limits,  and clear steps to avoid or correct deviations when working with energetic materials.     (f) PCP- 645- Stab Detonator- Automated Line; The operating procedure does not include the consequences of deviating from the safe operating limits,  and clear steps to avoid or correct deviations when working with energetic materials.     (g) GWI-SAF-24- Blasting Cap Shearing Operation; The operating procedure does not include the consequences of deviating from the safe operating limits,  and clear steps to avoid or correct deviations when working with energetic materials.    (h) PCP-569- M-6 Blasting Cap; The operating procedure does not include the consequences of deviating from the safe operating limits,  and clear steps to avoid or correct deviations when working with energetic materials.      (i) PCP-270- Body, Loaded; The operating procedure does not include the consequences of deviating from the safe operating limits,  and clear steps to avoid or correct deviations when working with energetic materials.     (j)GWI-EXP-1- Collection & Storage of Energetic Waste; The operating procedure does not include the consequences of deviating from the safe operating limits,  and clear steps to avoid or correct deviations when working with energetic materials.     (k)GWI- EXP-13- Handling and Cleanup of Overturned Powder Carriers; The operating procedure does not include the consequences of deviating from the safe operating limits,  and clear steps to avoid or correct deviations when working with energetic materials.

Issued

Jun 4, 2018

Abate by

Jun 3, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(iv): The employer failed to ensure that the Process Safety Management Standard Operating Procedures included safety systems and their functions:      (a) GWI-EXP-2 Burning Energetic Waste; The operating procedure does not include safety systems, their use, and function in mitigating the friction, heat, electrostatic discharge, and impact hazards when working with energetic materials.    (b) GWI-EXP-3 Burning Energetic Waste in Burn Troughs; The operating procedure does not include safety systems, their use, and function in mitigating the friction, heat, electrostatic discharge, and impact hazards when working with energetic materials.    (c) GWI-EXP-4- Burning Scrap Detonators; The operating procedure does not include safety systems, their use, and function in mitigating the friction, heat, electrostatic discharge, and impact hazards when working with energetic materials.       (d) GWI-EXP- 10- Breakdown of Bulk Primary; The operating procedure does not include safety systems, their use, and function in mitigating the friction, heat, electrostatic discharge, and impact hazards when working with energetic materials.    (e) GWI-EXP-6- Operating the Remote Drying and Metering Station; The operating procedure does not include safety systems, their use, and function in mitigating the friction, heat, electrostatic discharge, and impact hazards when working with energetic materials.    (f) PCP- 645- Stab Detonator- Automated Line; The operating procedure does not include safety systems, their use, and function in mitigating the friction, heat, electrostatic discharge, and impact hazards when working with energetic materials.       (g) GWI-SAF-24- Blasting Cap Shearing Operation;  The operating procedure does not include safety systems, their use, and function in mitigating the friction, heat, electrostatic discharge, and impact hazards when working with energetic materials.       (h) PCP-569- M-6 Blasting Cap ; The operating procedure does not include safety systems, their use, and function in mitigating the friction, heat, electrostatic discharge, and impact hazards when working with energetic materials.         (i) PCP-270- Body, Loaded; The operating procedure does not include safety systems, their use, and function in mitigating the friction, heat, electrostatic discharge, and impact hazards when working with energetic materials.      (j) GWI-EXP-1- Collection & Storage of Energetic Waste; The operating procedure does not include safety systems, their use, and function in mitigating the friction, heat, electrostatic discharge, and impact hazards when working with energetic materials.

Issued

Jun 4, 2018

Abate by

Mar 28, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(3): The operating procedures were not reviewed annually, or as often as necessary, to assure that they reflect current operating practice and changes  in process chemicals, technology, equipment, and the facility:     (a) GWI-EXP-2 Burning Energetic Waste; The operating procedure dated February 18, 2016 was not reviewed annually.    (b) GWI-EXP-3 Burning Energetic Waste in Burn Troughs; The operating procedure dated January 28, 2016 was not reviewed annually.     (c) GWI-EXP-4- Burning Scrap Detonators; The operating procedure dated January 28, 2016 was not reviewed annually.       (d) GWI-EXP-6- Operating the Remote Drying and Metering Station;  The operating procedure dated April 30, 2018 was not reviewed and updated to reflect changes in process procedures and equipment after the  incident on November 9, 2017.    (e) PCP- 645- Stab Detonator- Automated Line; The operating procedure dated April 12, 2012 was not reviewed annually.    (f) GWI-SAF-24- Blasting Cap Shearing Operation; The operating procedure dated December 15, 2014 was not reviewed annually.     (g) PCP-569- M-6 Blasting Cap; The operating procedure dated September 19, 2016 was not reviewed annually.      (h) GWI- EXP-13- Handling and Cleanup of Overturned Powder Carriers; The operating procedure dated September 27, 2011 was not reviewed annually.

Issued

Jun 4, 2018

Abate by

Mar 28, 2019

Penalty

Initial $4,837 · Current $3,385 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not certify that they had evaluated compliance with 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 are being followed:     (a) Throughout the facility; The employer did not conduct and did not certify that they had evaluated compliance with the provisions of 29 CFR 1910.119.