OSHA Inspection: DOLCO PACKAGING, LLC

Issued

Oct 17, 2018

Abate by

Dec 5, 2018

Penalty

Initial $6,652 · Current $4,989 Reduced

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:    a) On or about 4/19/2018, At the facility, Storage System:  The companies P & ID's did not accurately depict the system, discrepancies were such as, but not limited to:          - A liquid fill sight glass was present on the system past the transfer pumps, but was not present on the P & ID's.          - A liquid fill isolation valve was present on the system past the transfer pumps, but was not present on the P & ID's.          - A Pressure Relief Device was present on the system past the transfer pumps, but was not present on the P & ID's.    b) On or about 4/19/2018, At the facility, Pump Room:  The companies P & ID's did not accurately depict the system, discrepancies were such as, but not limited to:          - A new pump and delivery piping was not present on the P & ID's.     c) On or about 4/19/2018, At the facility, Extrusion Area: The companies P & ID's did not accurately depict the system, discrepancies were such as, but not limited to:          - A new extruder line (399) was not present on the P & ID's.          - Extruder lines 400, 401, and 402, did not have a heat exchanger on the system, but one was depicted on the P & ID's.          -Extruder lines 400, 401, 402 and 403 had numerous valves, gauges, accumulators and equipment present on the systems that were not depicted on the P & ID's.    Abatement certification is required for this item.

Issued

Oct 17, 2018

Abate by

Dec 5, 2018

Penalty

Initial $6,652 · Current $4,989 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(E): Information pertaining to the equipment in the process did not include a ventilation system design:    a) On or about 4/19/2018, At the facility, Pump Room and Extruder Area:  There were no ventilation system designs specifications or calculations maintained for the pump room and Extruder Area.    Abatement certification is required for this item.

Issued

Oct 17, 2018

Abate by

Dec 5, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:  a) On or about 4/19/2018, At the facility:  Ventilation for the process area and the pump room were not tested to ensure adequacy.  Abatement certification is required for this item.

Issued

Oct 17, 2018

Abate by

Jan 31, 2019

Penalty

Initial $6,652 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices:    a) On or about 4/19/2018, At the facility, Pump Room:  The pump room had a shared wall with the production building.  The shared wall consisted of a typical pre engineered steel building.  There were opening s in the shared wall.  The shared wall did not maintain a 1 hour fire rating, and was not capable of withstanding a 100 lb/ft^2 static pressure. The company did not maintain any design specifications on this pump room.  One potential source of RAGAGEP includes, but is not limited to NFPA 58, Liquefied Petroleum Gas Code, section 10.3.1.3.    b) On or about 4/19/2018, At the facility, Pump Room:  There were no ventilation design specifications on this pump room.   One potential source of RAGAGEP includes, but is not limited to NFPA 58, Liquefied Petroleum Gas Code, section 10.3.2.8.    Abatement certification is required for this item.

Issued

Oct 17, 2018

Abate by

Dec 5, 2018

Penalty

Initial $6,652 · Current $4,989 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not address the hazards of the process:    a) On or about 4/19/2018, At the facility:  The Process Hazard Analysis did not address the hazards associated with a ventilation fan failure in the pump room.    b) On or about 4/19/2018, At the facility:  The Process Hazard Analysis did not address the hazards associated with snow blockage of ventilation openings in the pump room.        c) On or about 4/19/2018, At the facility:  The Process Hazard Analysis did not address the failure/ damage to process piping due to falling ice and snow from adjacent roofs.       d) On or about 4/19/2018, At the facility:  The Process Hazard Analysis did not address the hazards associated with the opening of quarter turn dump valves at the extruders.       e) On or about 4/19/2018, At the facility:  The Process Hazard Analysis did not address the use of FR clothing for employees working around extruders, and responding to potential leaks.       Abatement certification is required for this item.

Issued

Oct 17, 2018

Abate by

Dec 5, 2018

Penalty

Initial $6,652 · Current $4,989 Reduced

General-duty citation text

29 CFR 1910.119(n): The employer did not implement an emergency plan for the entire plant in accordance with the provisions of 29 CFR 1910.38:    a) On or about 4/19/2018, At the facility:  The companies Emergency Response Program did not establish when evacuations were required/ mandatory.  Employees were not aware of what size fire required evacuation, or what percent of LEL would require an evacuation.        Abatement certification is required for this item.

Issued

Oct 17, 2018

Abate by

Dec 5, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.120(q)(6)(ii): First responders at the operational level did not receive at least eight hours of training or did not have sufficient experience to objectively demonstrate competency in the areas required by 29 CFR 1910.120(q)(6)(ii)(A) through (q)(6)(ii)(F) and/or the employer did not so certify:  a) On or about 4/19/2018, At the facility:  Employees were expected to respond to and mitigate leaks of flammable gas.  Employees were not provided with adequate training regarding the hazards associated with the releases they were responding to and appropriate release mitigation methods.     Abatement certification is required for this item.

Issued

Oct 17, 2018

Abate by

Dec 5, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.132(d)(1)(i): The employer did not select and have each affected employee use, the types of personal protective equipment that would protect the affected employee(s) from the hazards identified:  a) On or about 4/19/2018, At the facility:  Employees responding to, and mitigating flammable gas leaks were not provided with or required to wear flame resistant clothing.       Abatement certification is required for this item.

Issued

Oct 17, 2018

Abate by

Dec 5, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(1)(iii): The employer's program did not have information pertaining to the Physical properties of the product used in the process:  a) On or about 4/19/2018, At the facility:  The companies PSM program, section 4.0 Process Information/ Safety and Health, referenced supplement A (SDS) for information such as flash point, Boiling Point, Density, Ph, LEL, and UEL.  The provided SDS read "No Data Available" for these items.       Abatement certification is required for this item.