OSHA Inspection: ITW POLYMER SEALANTS NORTH AMERICA, INC.

Issued

Dec 10, 2018

Abate by

Dec 18, 2018

Penalty

Initial $12,934 · Current $5,750 Reduced

General-duty citation text

29 CFR 1910.28(b)(1)(i): The employer did not ensure that each employee on a walking-working surface with an unprotected side or edge that was 4 feet (1.2 m) or more above a lower level was protected from falling by one or more of the following:  Guardrail systems, safety net systems, or personal fall arrest systems:    Location:  Tank Farm catwalk, Reactor Room mezzanine, Gas House roof    Employees are inadequately protected against falls of up to approximately 10 feet 3 inches.    Instance A:  Catwalks used by employees to measure solvent levels in tanks lack mid-rails in some sections thereby exposing employees to fall hazards of approximately 9 feet 3 inches.    Instance B:   Employees going onto the Gas House roof to open valves and perform maintenance tasks are unprotected against falls of approximately 8 feet 6 inches.    Instance C: Employees unloading bags of dry ingredients are unprotected against a fall hazard of approximately 10 feet 3 inches.

Issued

Dec 10, 2018

Abate by

Dec 31, 2019

Penalty

Initial $10,163 · Current $4,700 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i): Process safety information pertaining to the equipment in the process did not include the elements specified in 29 CFR 1910.119(d)(3)(i)(A) through (H):    Location:  Tank Farm, Reactor Room, Churn Room, Clay Mix Room    Instance A:  The Reactor lacked a name plate which indicated its maximum allowable working pressure and temperature, date of installation and other required information.    Instance B:  The company did not have design and design basis information for hydrostatic relief valves for the A70 and DME propellant piping.    Instance C:  The company did not have ventilation design information for the Churn Room and its ventilation design information for the Clay Mix Room is inadequate.

Issued

Dec 10, 2018

Abate by

Jan 31, 2019

Penalty

Initial $10,163 · Current $4,700 Reduced

General-duty citation text

29 CFR 1910.119(e)(3): The process hazard analysis did not address the elements of (i) through (vii) of this paragraph:    Location:  Tank Farm, Gas House, Reactor Room, Churn Room, Clay Mix Room    The "What-If " process hazard analysis did not identify all the engineering and administrative controls needed to manage the consequences of failure of equipment, safe work practices, etc.    Instance A:  The What-If analysis does not indicate how safety will be maintained in the event of a power outage.    Instance B:  The What-If analysis does not indicate how hazards associated with the rupture of propellant piping will be addressed.    Instance C: The What-If analysis does not address the failure of propellant tanks due to mechanical damage such as their being struck by nearby collapsing vertical tanks.    Instance D:  The What-If analysis does not identify a closed input valve which causes a delivery hose to burst or blow off the valve as a potential hazard.    Instance E:  The What-If analysis does not indicate how the hazards associated with blocked or otherwise malfunctioning ventilation will be addressed.

Issued

Dec 10, 2018

Abate by

Dec 24, 2018

Penalty

Initial $10,163 · Current $4,700 Reduced

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:    Location:  Tank Farm, Gas House, Reactor Room    Equipment such as valves are not being locked out prior to maintenance work being performed on them.

Issued

Dec 10, 2018

Abate by

Dec 18, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(f)(1)(ii): Employees were not removed from the machine or equipment area in accordance with paragraph (e)(2) of this section during testing or positioning of machines, equipment or components thereof.  Location:  Prosys Room  An employee was not removed from the machine area during the troubleshooting of the shrink wrap machine arm.  He was seriously injured when the machine arm activated and struck him in the head.

Issued

Dec 10, 2018

Abate by

Jan 31, 2019

Penalty

Initial $10,163 · Current $4,700 Reduced

General-duty citation text

29 CFR 1910.119(g)(1)(i): The employer did not train each employee before being involved in operating a newly assigned process in the operating procedures as specified in paragraph (f) of this section.    Facility:  Tank Farm, Gas House, Reactor Room, Churn Room, Clay Mix Room    Employees have not been adequately trained on the process operating procedures for PSM covered processes.

Issued

Dec 10, 2018

Abate by

Jan 31, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(g)(2): Refresher training was not provided at least every three years to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process:    Location:  Tank Farm, Gas House, Reactor Room    Employees have not received refresher training of an overview of the process operating procedures for PSM covered processes.

Issued

Dec 10, 2018

Abate by

Jan 31, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(g)(3):   Training documentation. The employer do not ascertain that each employee involved in operating a process had received and understood the training required by this paragraph. The employer did not prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.    Location:    Tank Farm, Gas House, Reactor Room, Churn Room, Clay Mix Room.    The company has not prepared sufficient written records documenting that its employees have received training on operating procedures for PSM covered processes.

Issued

Dec 10, 2018

Abate by

Jun 30, 2020

Penalty

Initial $12,934 · Current $5,750 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment to maintain its mechanical integrity, was not consistent with applicable manufacturer's recommendations and good engineering practices, or more frequently determined to be necessary by prior operating experience.        Location:  Tank Farm, Gas House, Reactor Room    The company has not performed inspections and tests of process equipment consistent with applicable manufacturers' recommendations and good engineering practices.

Issued

Dec 10, 2018

Penalty

Initial $10,163 · Current $4,700 Reduced

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means were taken to assure safe operation:    Location:  Tank Farm    For several years, vertical solvent tanks were inadequately protected against wind and seismic loads.  Had they collapsed, they could have severely damaged nearby propellant tanks and piping and produced a catastrophic release of propellant.