OSHA Inspection: CAPCO LLC

Issued

Jan 28, 2019

Abate by

May 1, 2019

Penalty

Initial $8,051 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(H): The employer's compiled written process safety information did not include all the necessary information pertaining to the equipment in the process in that the process safety information did not include specific information with regards to safety systems:    (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer did not ensure that the compiled written process safety information included all the necessary information pertaining to the equipment in the process in that the process safety information did not include specific information with regards to safety systems.  The employer manufactured explosives during the production of electrically ignited impulse cartridges.  The explosive component of the cartridges was a DOT 1.3 explosive compound.  The employer did not include in the process safety information that of safety system process equipment including, but not limited to the following.  This condition exposed employees to an explosion hazard.    1.    ELR fire suppression system;  2.    ELR humidity monitoring system and alarm; and  3.    Water heater controllers and over-temperature shut off system.

Issued

Jan 28, 2019

Abate by

Jun 15, 2019

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 (RAGAGEP):    (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP).  The employer manufactured explosives during the production of electrically ignited impulse cartridges.  The explosive component of the cartridges was a DOT 1.3 explosive compound.  The employer utilized multiple pieces of in-house designed and built equipment and manufactured equipment throughout the process.  The employer did not document that equipment, such as but not limited to the following, complied with RAGAGEP, such as but not limited to Department of Defense DOD 6055.9-STD "DOD Ammunition and Explosives Safety Standards".  This condition exposed employees to an explosion hazard.    1.    1/4" Lexan used as impact protection;  2.    Water heated ovens and controllers;  3.    Ross model 100ML High Shear Mixer;   4.    Pneumatic press for loading slurry into hoppers;  5.    Pneumatic press for installing initiator onto can;  6.    Electronic press for consolidating initiator with bridge wire;  7.    Pneumatic press for installing puncture pin; and  8.    Miyashi Unitek model LW150A/Delta Workstation laser welder.

Issued

Jan 28, 2019

Abate by

Apr 15, 2019

Penalty

Initial $8,051 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(ii):  The employer's process hazard analysis did not identify any previous incidents which had a likely potential for catastrophic consequences in the workplace:    (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer's process hazard analysis did not identify any previous incidents which had a likely potential for catastrophic consequences in the workplace.  The employer manufactured explosives during the production of electrically ignited impulse cartridges.  The explosive component of the cartridges was a DOT 1.3 explosive compound.  Multiple ignitions of explosives occurred during 2017.  The employer created a PHA for each specific step of the process.  The PHAs did not identify the previous incidents.  This condition exposed employees to an explosion hazard.

Issued

Jan 28, 2019

Abate by

May 1, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(iv):  The employer's process hazard analysis did not address consequences of failure of engineering and administrative controls:  (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer's process hazard analysis did not address consequences of failure of engineering and administrative controls.  The employer manufactured explosives during the production of electrically ignited impulse cartridges.  The explosive component of the cartridges was a DOT 1.3 explosive compound.  The employer utilized engineering controls to prevent ignition of the explosives.  The employer's PHA did not address consequences of failure for the following, but not limited to, engineering controls.  This condition exposed employees to an explosion hazard.  1.    Failure of the oven water heater temperature control; 2.    Failure of the oven water heater over-temperature shutdown system; 3.    Failure of the ELR humidity monitor and/or alarm; and  4.    Failure of the computer control or force monitor for the electronic press in the ELR.

Issued

Jan 28, 2019

Abate by

May 1, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(v): The employer's process hazard analysis did not address facility siting:  (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer's process hazard analysis did not address facility siting.  The employer manufactured explosives during the production of electrically ignited impulse cartridges.  The explosive component of the cartridges was a DOT 1.3 explosive compound.  The employer's PHA did not address facility siting.  This condition exposed employees to an explosion hazard.

Issued

Jan 28, 2019

Abate by

May 1, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The employer's process hazard analysis did not address human factors:  (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer's process hazard analysis did not address human factors.  The employer manufactured explosives during the production of electrically ignited impulse cartridges.  The explosive component of the cartridges was a DOT 1.3 explosive compound.  The employer's PHA did not address human factors.  This condition exposed employees to an explosion hazard.

Issued

Jan 28, 2019

Abate by

May 1, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(4): The employer's process hazard analysis was not performed by a team that included at least one employee who was knowledgeable in the specific process hazard analysis methodology being used:  (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer's process hazard analysis was not performed by a team that included at least one employee who was knowledgeable in the specific process hazard analysis methodology being used.  The employer manufactured explosives during the production of electrically ignited impulse cartridges.  The explosive component of the cartridges was a DOT 1.3 explosive compound.  The employer utilized a What If methodology for its process hazard analysis.  The team did not contain at least one employee who was knowledgeable of how to perform a comprehensive What If process hazard analysis.  This condition exposed employees to an explosion hazard.

Issued

Jan 28, 2019

Abate by

Jun 15, 2019

Penalty

Initial $8,051 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment:    (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer did not establish and implement written procedures to maintain the on-going integrity of process equipment.  The employer manufactured explosives during the production of electrically ignited impulse cartridges.  The explosive component of the cartridges was a DOT 1.3 explosive compound.  The employer utilized multiple pieces of in-house designed and built equipment and manufactured equipment throughout the process.  The employer did not establish and implement written procedures to maintain emergency shutdown system equipment and controls equipment, such as but not limited to the following.  This condition exposed employees to an explosion hazard.    1.    Water heater over-temperature shutdown system for ovens;  2.    Water heater temperature control for ovens;  3.    ELR initiator electronic press force monitor/control system; and  4.    ELR humidity monitor and alarm system.

Issued

Jan 28, 2019

Abate by

May 1, 2019

Penalty

Initial $8,051 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process:    (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer did not establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.  The employer manufactured explosives during the production of electrically fired impulse cartridges.  The explosive component of the cartridges was a DOT 1.3 explosive compound.  Cartridges were sealed using a laser welder.  A modification to the laser welder was done in response to ignitions of the explosive during welding.  This was a change to the process.  The employer had not established and implemented written procedures to manage changes to processes.  This condition exposed employees to an explosion hazard.    (b)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer did not establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.  The employer manufactured explosives during the production of electrically fired impulse cartridges.  The explosive component of the cartridges was a DOT 1.3 explosive compound.  A modification to a press's ram and the introduction of an automated pressing operation took place in response to ignitions of the explosive during consolidation.  These were changes to the process.  The employer had not established and implemented written procedures to manage changes to processes.  This condition exposed employees to an explosion hazard.

Issued

Jan 28, 2019

Abate by

Jun 15, 2019

Penalty

Initial $8,051 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not certify that they had evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard were adequate and were being followed:    (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer did not certify that they had evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard were adequate and were being followed.  The employer manufactured explosives during the production of electrically ignited impulse cartridges.  The explosive component of the cartridges was a DOT 1.3 explosive compound.  The employer had not evaluated the entirety of its process safety management program in the past three years.  This condition exposed employees to an explosion hazard.

Issued

Jan 28, 2019

Abate by

Mar 4, 2019

Penalty

Initial $4,831 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.303(b)(2): Listed or labeled equipment was not installed and used in accordance with any instructions included in the listing or labeling:    (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer did not ensure that listed or labeled equipment was installed and used in accordance with any instructions included in the listing or labeling.  Employees used Kester Leaded solder (containing 37% lead), Kester Lead Bar Solder (containing 37% lead),  Kester silver/tin solder, and Superior Flux 515 (containing 4-10% hydrobromic acid) when soldering circuit boards.  During the soldering process, excess flux was rinsed off in Hamilton Beach model SC38 consumer grade slow cookers containing de-ionized water.  The slow cookers were modified by the employer and were operated during the entire shift each day of the work week.  The Hamilton Beach slow cookers were not installed or used in accordance with the listing for the slow cooker.  This condition exposed employees to an electrical hazard.

Issued

Jan 28, 2019

Abate by

Mar 4, 2019

Penalty

Initial $4,831 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.332(b)(1): Employees were not trained in and familiar with the safety-related work practices required by 1910.331 through 1910.335 that pertain to their respective job assignments:    (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On or about 8/21/18 and preceding, the employer did not ensure that employees were trained in and familiar with the safety-related work practices required by 1910.331 through 1910.335 that pertain to their respective job assignments.  The employer used a Miyashi Unitek model LW-150A laser power supply to perform laser welding.  The laser and chiller were powered by 220v electricity.  The lamp for the laser, located in the chiller unit of the power supply, was replaced when it no longer functioned.  The employee had only turned "off" the power at the work station.  The employee had not received training related to electrical safety-related work practices to perform this task.  This condition exposed the employee to an electrical hazard.

Issued

Jan 28, 2019

Abate by

Mar 4, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.333(a)(1): Live parts to which an employee may be exposed were not de-energized before the employee worked on or near them:  (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On or about 8/21/18 and preceding, the employer did not ensure that procedures were developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section.  The employer used a Miyashi Unitek model LW-150A laser power supply to perform laser welding.  The laser and chiller were powered by 220v electricity.  The lamp for the laser, located in the chiller unit of the power supply, was replaced when it no longer functioned.   An employee, when performing this maintenance, opened the chiller to replace the lamp.  The employee had only turned "off" the power at the work station.  The employee did not de-energize the electrical power.  This condition exposed the employee to an electrical hazard.

Issued

Jan 28, 2019

Abate by

Apr 1, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(d)(1)(iii): The employer did not identify and evaluate the respiratory hazard in the workplace:  (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer did not identify and evaluate the respiratory hazard in the workplace.  Employees used Kester solder, containing silver and tin, when soldering circuit boards.  The employer did not determine employee exposure to silver or tin.  This condition potentially exposed employees to a respiratory hazard.

Issued

Jan 28, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(d)(2): An initial determination was not made to determine if any employee may be exposed to lead at or above the action level:  (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer did not ensure that an initial determination was made to determine if any employee may be exposed to lead at or above the action level.  Employees used Kester Leaded solder (containing 37% lead) or Kester Lead Bar Solder (containing 37% lead) when soldering circuit boards.  The employer did not determine employee exposure to lead when soldering circuit boards.  This condition potentially exposed employees to a lead hazard.

Issued

Jan 28, 2019

Abate by

Mar 4, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(e)(1): The employer did not provide a medical evaluation to determine the employee's ability to use a respirator, before the employee was fit tested, or required to use the respirator in the workplace:    (a)  Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer did not provide a medical evaluation to determine the employee's ability to use a respirator, before the employee was fit tested, or required to use the respirator in the workplace.  An employee transferred Cabot Corporation Cab-o-sil (containing fumed amorphous silica) from its primary container to a transport container prior to blending.  The employee was required to wear a 3M model 8271 P95 filtering facepiece respirator while performing this operation.  The employer did not provide a medical evaluation to each employee required to wear a respirator when working with Cab-o-sil.  This condition potentially exposed the employee to a respiratory hazard.

Issued

Jan 28, 2019

Abate by

Mar 4, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(k)(1): The employer did not provide effective, comprehensive, understandable, annual respirator training to employees who are required to use respirators:  (a) Capco LLC, at 1328 Winters Avenue, Grand Junction, CO: On and preceding 9/11/18, the employer did not provide effective, comprehensive, understandable, annual respirator training to employees who are required to use respirators.  An employee transferred Cabot Corporation Cab-o-sil (containing fumed amorphous silica) from its primary container to a transport container prior to blending.  The employee was required to wear a 3M model 8271 P95 filtering facepiece respirator while performing this operation.  The employer did not provide annual comprehensive respirator training to employees required to wear a respirator when working with Cab-o-sil.  This condition potentially exposed the employee to a respiratory hazard.