OSHA Inspection: KURARAY AMERICA, INC

Issued

Nov 14, 2018

Abate by

Dec 19, 2018

Penalty

Initial $11,641 · Current $11,641

Hazardous substances 11152572

General-duty citation text

29 CFR 1910.119(e)(1): The process hazard analysis was not appropriate to the complexity of the process and did not identify, evaluate, and control the hazards involved in the process:   On or about May 19, 2018 and at times prior thereto at the Kuraray EVAL manufacturing facility in Pasadena, Texas, the evaluation of relief valve vents in the process hazard analysis for the 1200 polymerization process:    (a) Does not identify and evaluate phase change of ethylene   (e) The level of protection analysis for R-1201 is based on PSI for equipment not in the process   (f)  Did not identify risks for persons being in the relief valve vent/exhaust zone performing work while the reactor operates in unstable/upset condition.

Issued

Nov 14, 2018

Abate by

Dec 19, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process.  On or around May 19, 2018 and at times prior thereto, at the Kuraray EVAL facility in Pasadena, Texas, the PHA revalidations for the 1200 Polymerization Process did not address hazards of the process:    (a) The reactor pressure in the PHA analyses is not consistent with the R-1201 reactor of the 1200 Polymerization process.

Issued

Nov 14, 2018

Abate by

Dec 19, 2018

Penalty

Initial $11,641 · Current $11,641

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not assure that process hazard analysis recommendations were resolved in a timely manner and that the resolution is documented and communicated to operating, maintenance and other employees who may be affected by the recommendations or actions.  On or about May 19, 2018 and at times prior thereto at the Kuraray EVAL manufacturing facility in Pasadena, Texas, the employer did not develop a written schedule describing when corrective actions related to resolution and any interim measures to assure safe operations will be completed.

Issued

Nov 14, 2018

Abate by

Dec 19, 2018

Penalty

Initial $0 · Current $0

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 around May 19, 2018 and at times prior thereto at the Kuraray EVAL manufacturing facility in Pasadena, Texas the employer did not document that the relief system for reactor R-1201 complies with recognized and generally accepted good engineering practices.

Issued

Nov 14, 2018

Abate by

Dec 19, 2018

Penalty

Initial $11,641 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.119(g)(1)(i): Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks.  On or around May 19, 2018 and at times prior thereto, at the Kuraray EVAL facility in Pasadena, Texas, the employer did not effectively implement training on the safe operating limits and consequences of deviation.

Issued

Nov 14, 2018

Abate by

Dec 19, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(A): The employer did not develop and implement written operating procedures that address consequences of deviation.   On or around May 19, 2018 and at times prior thereto, at the Kuraray EVAL facility in Pasadena, Texas the employer did not develop and implement written operating procedures for the 1200 Polymerization process that were consistent with process safety information, addressing consequences of deviation from operating limits.

Issued

Nov 14, 2018

Abate by

Dec 19, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 1115

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(B): The employer did not develop and implement written operating procedures that provide clear instructions for steps required to correct or avoid deviation from the operating limits in the covered process.  On or around May 19, 2018 and at times prior thereto in the 1200 Polymerization process, the employer did not implement written operating procedures that provide clear instructions for steps required to correct or avoid deviation from operating limits to prevent over-pressuring the reactor with ethylene during startup.

Issued

Nov 14, 2018

Abate by

Dec 19, 2018

Penalty

Initial $11,641 · Current $11,641

General-duty citation text

29 CFR 1910.119(f)(4): The employer did not develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel:  On or around May 19, 2018 the employer did not implement safe work practices to remove maintenance, project support, and other non-essential personnel from process areas when the unit experienced upset conditions when:    (c) EDN Project support, maintenance, and contract workers were not removed from areas around the 1200 Polymerization process when the HIGH-HIGH pressure alarm on the DCS for R-1201 was activated to warn that reactor pressure exceeded normal operating pressures.

Issued

Nov 14, 2018

Abate by

Dec 19, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 1115

General-duty citation text

29 CFR 1910.119(h)(2)(iv): The employer did not develop and implement safe work practices consistent with paragraph (f)(4) of this section to control the entrance, presence and exit of contract employers and contract employees in the covered process areas.  On or around May 19, 2018 in Block 1 of its process area at the Kuraray EVAL facility in Pasadena, TX the employer did not implement safe work practices to control presence and exit of contract employers and contract employees in the covered process areas when:    (a) Employer did not remove Force Corporation from the unit when the process became unstable and exposed workers to  hazards of ethylene from the process   (b) Employer did not remove Industrial Solutions Inc.  from the unit when the process became unstable and exposed workers to hazards of ethylene from the process   (c) Employer did not inform Certified Safety  from the unit when the process became unstable and exposed workers to hazards of ethylene from the process   (d) Employer did not inform Universal Plant Services from the unit when the process became unstable and exposed workers to hazards of ethylene from the process   (e) Employer did not inform Ardent Services  from the unit when the process became unstable and exposed workers to hazards of ethylene from the process   (f) Employer did not inform Chemic Engineers  from the unit when the process became unstable and exposed workers to hazards of ethylene from the process

Issued

Nov 14, 2018

Abate by

Dec 19, 2018

Penalty

Initial $11,641 · Current $11,641

General-duty citation text

29 CFR 1910.119(h)(2)(ii):  The employer did not inform contract employees of potential fire, explosion or toxic release hazards related to working on or near a covered process.  On or around May 19, 2018 in Block 1 of its process area at the Kuraray EVAL facility in Pasadena, TX, the employer did not inform contract employees of potential hazards of release of flammable materials from the 1201 reactor while in upset condition.    (a) Employer did not inform Force Corporation of elevated pressure and potential release hazard   (b) Employer did not inform Industrial Solutions Inc. of elevated pressure and potential release hazard   (c) Employer did not inform Certified Safety of elevated pressure and potential release hazard   (d) Employer did not inform Universal Plant Services of elevated pressure and potential release hazard   (e) Employer did not inform Ardent Services of elevated pressure and potential release hazard   (f) Employer did not inform Chemic Engineers of elevated pressure and potential release hazard

Issued

Nov 14, 2018

Abate by

Dec 19, 2018

Penalty

Initial $11,641 · Current $11,641

Hazardous substances 11152572

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not implement procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process  On or around May 19, 2018 at the Kuraray EVAL facility in Pasadena, Texas the employer did not implement its interlock bypass procedure to manage change when:   (a) interlock ILK-1203, which prevents over-pressure of the R-1201 reactor, was bypassed during startup of the 1200 polymerization process.   (b) interlock ILK-1204, which vents reactor pressure to flare and protects the R-1201 reactor from abnormal high pressure was not activated.

Issued

Nov 14, 2018

Abate by

Dec 19, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(3): Operating procedures were not reviewed as often as necessary to assure that they reflect current operating practice.   On or around May 19, 2018 and at times prior thereto, at the Kuraray EVAL manufacturing facility in Pasadena, Texas the employer did not ensure written operating procedures were current and accurately reflected instructions for starting up the 1201 Reactor in the 1200 Polymerization process unit following a turnaround.

Issued

Nov 14, 2018

Abate by

Dec 19, 2018

Penalty

Initial $933 · Current $933

Hazardous substances 1115

General-duty citation text

29 CFR 1910.119(m)(3): The incident investigation team did not consist of at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident:  The employer did not include a representative of the contractor whose work may have affected the incident when investigating and analyzing the incident that occurred at the Kuraray EVAL site in Pasadena, Texas, that occurred May 19, 2018.     (e) The incident investigation team did not include Certified Safety