OSHA Inspection: THE LUBRIZOL CORPORATION

Issued

Apr 1, 2019

Abate by

Apr 22, 2019

Penalty

Initial $4,831 · Current $3,600 Reduced

General-duty citation text

29 CFR 1910.28(b)(11)(ii):The employer does not ensure each flight of stairs having at least 3 treads and at least 4 risers are equipped with stair rail systems and handrails per Table D-2;     a) Lubrizol Facility located at 76 Porcupine Road, Pedricktown, NJ, Tank Farm, Near Piping labelled as CAS#141-32-2: The stairway, containing 6 risers and used to access the catwalk area, was  not equipped with an adequate stair rail system. The stairway was missing a stair rail on the open side, on or about 10/11/2018.    b) Lubrizol Facility located at 76 Porcupine Road, Pedricktown, NJ, Tank Farm, Near LDAR TF 1187: The stairway, containing 5 risers and used to access the catwalk area, was  not equipped with an adequate stair rail system. The stairway was missing a stair rail on the open side, on or about 10/11/2018.        To abate this violation, the employer must ensure that each set of stairs having at least 3 treads and at least 4 risers is equipped with stair rail systems (top, intermediate rail and where there is a hazard for falling objects a toeboard) and handrails.    NOTE:  THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM, FAILURE TO DO SO WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 AS PER 29 CFR 1903.19.

Issued

Apr 1, 2019

Abate by

Apr 22, 2019

Penalty

Initial $8,050 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): Information pertaining to the equipment in the process did not include Piping & Instrumentation Diagrams:    a) Lubrizol Facility located at 76 Porcupine Road, Pedricktown, NJ, Acrylic Emulsion Batch Process, Building 502, Third Floor, Pre Mix Reactor 1 TK-5Q: The employers P&ID, GPC-0130 Revision L, did not include existing process equipment present at the Pre-Mix Reactor 1 TK-5Q.  A hand valve, pressure indicator, and pressure indicator installed off an 8 pipe, as well as an unused 4 opening, were not depicted on the P&ID, on or about 1/28/19.        NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Apr 1, 2019

Abate by

Dec 30, 2021

Penalty

Initial $13,260 · Current $8,600 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the team's findings and recommendations; assure that the recommendations were resolved in a timely manner and that the resolution was documented; document what actions were to be taken; complete actions as soon as possible; develop a written schedule of when these actions were to be completed; communicate the actions to operating, maintenance and other employees whose work assignments were in the process and who may be affected by the recommendations or actions.    On or about October 11, 2018, at the Lubrizol Facility located at 76 Porcupine Road, Pedricktown, NJ:       a)    Location: 001 Eng/HAS/Acct trailer and the 002 Storage Trailer. The employer did not address the 2014 Facility Siting Report's recommendations regarding these portable trailers. The report identified the trailers being located in Zone 1, where they could explode, collapse, or contain a dangerous atmosphere in the event of an uncontrolled release at the facility. Employees worked in these trailers and were exposed to the hazards.      b)    Location: Blend Tech Office inside Building 502, floor 2. The employer did not address the 2014 Facility Siting Report's recommendation regarding this modular building inside Building 502. The report identified explosion, collapse, and dangerous atmosphere hazards for this building in the event of an uncontrolled release at the facility. Employees worked in the modular office and were exposed to the hazards.      c)     Location: Buildings 004, 005, 502-2, 502-3, 502-4, 502, and 506. The employer did not address the 2014 Facility Siting Report's recommendations regarding structural and non-structural hazards, including windows and doors, in these buildings. The report identified explosion, collapse, and dangerous atmosphere hazards for these building in the event of an uncontrolled release at the facility. Employees worked in these buildings and were exposed to the hazards.        NOTE:  IN ADDITION TO ABATEMENT CERTIFICATION, THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT DOCUMENTATION FOR THIS ITEM, FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Apr 1, 2019

Abate by

Jul 15, 2019

Penalty

Initial $8,050 · Current $5,200 Reduced

General-duty citation text

29 CFR 1910.120(q)(2)(iii): The emergency response plan did not address, to the extent not addressed elsewhere,  emergency recognition and prevention:    a) Lubrizol Facility located at 76 Porcupine Road, Pedricktown, NJ, Acrylic Emulsion Batch Process: The employer's emergency response plan did not address or define the differences between a small leak and a large leak, on or about 10/3/2018.    b) Lubrizol Facility located at 76 Porcupine Road, Pedricktown, NJ, Acrylic Emulsion Batch Process: Lubrizol employees serving on the plant-wide emergency response team respond to emergencies involving chemical releases at the shared Pedrickstown Complex facility.  The joint Emergency Response Plan did not include the hazards associated with chemicals used by Lubrizol, including, but not limited to: Ethyl Acrylate, Acrylonitrile, and Styrene., on or about 10/3/2018.    NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Apr 1, 2019

Abate by

Jul 15, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.120(q)(2)(ix): The emergency response plan did not address, to the extent not addressed elsewhere, emergency alerting and response procedures:    a) Lubrizol Facility located at 76 Porcupine Road, Pedricktown, NJ, Acrylic Emulsion Batch Process: Lubrizol employees participate as responders on the plant-wide emergency response team. The plant-wide emergency response program did not address at which levels the release/spill should be handled internally or when the plant-wide emergency response team should be utilized, on or about 10/3/2018.    NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Apr 1, 2019

Abate by

Jul 15, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.120(q)(2)(xi): The emergency response plan did not address, to the extent not addressed elsewhere,  personal protective equipment and emergency equipment:    a) Lubrizol Facility located at 76 Porcupine Road, Pedricktown, NJ, Acrylic Emulsion Batch Process: The employer's emergency response plan did not address the required personal protective equipment when responding to chemical spills/leaks, on or about 10/3/2018.    NOTE: THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM. FAILURE TO COMPLY WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 IN ACCORDANCE WITH 29 CFR 1903.19.

Issued

Apr 1, 2019

Abate by

Jul 15, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.165(b)(2): The employee alarm could not be perceived above ambient noise or light levels by all employees in the affected portions of the workplace:    a) Lubrizol Facility located at 76 Porcupine Road, Pedricktown, NJ, Engineering and Accounting Trailer:  The employer failed to provide a means to alert employees, working in the trailer, of a chemical release or a fire within the facility. The trailer is not equipped with an alarm system, on or about 10/11/2018.    b) Lubrizol Facility located at 76 Porcupine Road, Pedricktown, NJ, Purchasing Trailer:  The employer failed to provide a means to alert employees, working in the trailer, of a chemical release or a fire within the facility. The trailer is not equipped with an alarm system, on or about 10/11/2018.    NOTE:  THE EMPLOYER IS REQUIRED TO SUBMIT ABATEMENT CERTIFICATION FOR THIS ITEM, FAILURE TO DO SO WILL RESULT IN AN ADDITIONAL PENALTY OF $1000.00 AS PER 29 CFR 1903.19.