OSHA Inspection: KEY AUTOMOTIVE OF FLORIDA, INC. AND ITS SUCCESSORS

Issued

Sep 4, 2018

Abate by

Oct 31, 2018

Penalty

Initial $12,934 · Current $7,800 Reduced

General-duty citation text

29 CFR 1910.38(f)(2): The employer did not review the emergency action plan with each employee covered by the plan when the employee's responsibilities under the plan changed.    a) On or about 04/18/2018, employees working in building 9 who had transferred from other buildings were not trained on the evacuation procedures and route from building 9.

Issued

Sep 4, 2018

Abate by

Apr 1, 2019

Penalty

Initial $9,239 · Current $6,179 Reduced

General-duty citation text

29 CFR 1910.119(c)(3): The employer did not provide employees and their representatives access to process hazard analyses and to all other information required to be developed under this standard:    a) On or about 03/07/2018, at the Key Automotive Lakeland facility, employees were not aware of what a process hazard analysis was or what a process safety management program was and how to access them.

Issued

Sep 4, 2018

Abate by

Apr 1, 2019

Penalty

Initial $12,934 · Current $9,000 Reduced

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) At the Key Automotive facility at 5300 Allen K Breed Highway, Lakeland, FL, on or about 3/9/2018, the initial process analysis conducted in 1994 and the revalidations conducted in 2010/2011 did not address the consequences of the failure of engineering and administrative controls such as, but not limited to, the following:    - Explosion walls  - Controls for fire alarm and deluge system  - Scrubber interlock  - Door interlocks  - Amp meters  - Temperature alarms  - Drive interlock for process shut-down  - High Temperature alarm  - Steam Temperature limit  - PIC 236 for vent damper of dryer  - Limit switch on oven circulation fan  - Motor controls for the tumbling operation  - Door interlocks for the presses  - Temperature sensor on the mixer for the Teledyne  - Amperage sensor on motor for the Teledyne  - Amperage sensor on motor for the Alexanderwerks  - Amperage sensor of feeder motor for Accurate Feeder  - Overtemp control for the boiler  - Blowout walls for pressure relief  - Administrative control for the grounding of bins at all times

Issued

Sep 4, 2018

Abate by

Apr 1, 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) At the Key Automotive facility at 5300 Allen K Breed Highway, Lakeland, FL, on or about 3/9/2018, for the process hazard analysis conducted in 1994/1996 and the subsequent process hazard analysis revalidation conducted in 2010/2011, human factors were not discussed for scenarios such as, but not limited, abnormal operation conditions.

Issued

Sep 4, 2018

Abate by

Apr 1, 2019

Penalty

Initial $12,934 · Current $9,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(4): The process hazard analysis was not performed by a team with expertise in engineering and process operations:    a) At the Key Automotive facility at 5300 Allen K Breed Highway, Lakeland, FL, on or about 03/09/2018, the last process hazard analysis performed in 2010/2011 was completed by one person instead of a team with expertise in engineering and process operations.

Issued

Sep 4, 2018

Abate by

Apr 1, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(6): The process hazard analysis was not updated and revalidated every five years:    a) At the Key Automotive facility at 5300 Allen K Breed Highway, Lakeland, FL, on or about 03/09/2018, the last process hazard analysis had been performed in 2010/2011.

Issued

Sep 4, 2018

Abate by

Apr 1, 2019

Penalty

Initial $12,934 · Current $9,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(A): 29 CFR 1910.119(f)(1)(iii)(A): Operating procedures did not address properties of, and hazards presented by, the chemicals used in the process:    (a) On or about 03/16/2018, operating procedures did not address the properties of the chemicals used in the covered process. The covered process contained multiple chemicals that were reactive and/or explosive.

Issued

Sep 4, 2018

Abate by

Apr 1, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(C): The employer failed to ensure that the Process Safety Management Standard Operating Procedures included safety and health considerations such as control measures to be taken if physical contact or airborne exposure occurs:    a) On or about 03/16/2018, operating procedures for the covered process did not address what measures were to be taken if physical contact or airborne exposure of chemicals occurs. Chemicals used in the covered process presented skin contact, respiratory, and fire/explosion hazards.

Issued

Sep 4, 2018

Abate by

Apr 1, 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) On or about 03/16/2018, operating procedures did not include safety systems such as, but not limited to, interlocks, blow out walls and suppression and deluge systems.

Issued

Sep 4, 2018

Abate by

Dec 31, 2018

Penalty

Initial $12,934 · Current $8,700 Reduced

General-duty citation text

29 CFR 1910.147(c)(4)(i): Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:    a) On or about 04/18/2018, at the site, specific lockout tagout procedures were not developed for process equipment, such as but not limited to mills, granulators, presses and dryers, on which service and maintenance was performed in the generant processing sections. Hazardous energy existed in the form of electricity (110VAC - 480VAC), compressed air and explosion hazards from the chemicals used.

Issued

Sep 4, 2018

Abate by

Oct 31, 2018

Penalty

Initial $12,934 · Current $8,700 Reduced

General-duty citation text

29 CFR 1910.147(c)(5)(ii)(D): Lockout devices and tagout devices did not indicate the identity of the employee applying the device(s):    a) On or about 03/21/2018, in building #9, locks used by operation employees performing tear down maintenance on equipment such as, but not limited to, presses, grannulators, mills, and other particle size modification equipment did not identify the person working on the equipment, and tags were not used.

Issued

Sep 4, 2018

Abate by

Dec 31, 2018

Penalty

Initial $12,934 · Current $8,700 Reduced

General-duty citation text

29 CFR 1910.147(d)(3): All energy isolating devices that were needed to control the energy to the machine or equipment were not physically located and operated in such a manner as to isolate the machine or equipment from the energy source(s):    a) On or about 04/18/2018, in building 9, employees used an e-stop instead of an energy isolating device to shut off a wet mix/granulation process. Hazardous energy existed in the form of moving parts - rotating screws.

Issued

Sep 4, 2018

Abate by

Oct 31, 2018

Penalty

Initial $12,934 · Current $8,700 Reduced

General-duty citation text

29 CFR 1910.147(f)(3)(ii)(D): Each authorized employee did not affix a personal lockout or tagout device to the group lockout device before working on the machine or equipment:    a) On or about 04/18/2018, in building 9, employees performed maintenance on equipment such as, but not limited to, presses, grannulators, mills and other particle size modification equipment. Hazardous energy sources existed in the form of moving/rotating parts, compressed air and explosive energy from chemicals present. Multiple employees worked simultaneously under one lock/tag during tear downs and other maintenance activities, and each authorized employee did not have their own lock/tag to place on the energy isolating device.

Issued

Sep 4, 2018

Abate by

Oct 31, 2018

Penalty

Initial $12,934 · Current $7,800 Reduced

General-duty citation text

29 CFR 1910.1200(h)(3)(ii): Employee training did not include the physical and health hazards of the chemicals in the work area:    a) On or about 03/21/2018, employees working in covered process buildings who worked with chemicals such as, but not limited to, strontium nitrate, potassium, mica, boron, nitroguanadine and 5AT were not aware of the hazards of the chemicals they worked with. Hazards of the chemicals used included respiratory, skin contact and explosive hazards.