OSHA Inspection: PHOTOFABRICATION ENGINEERING, INC.

Issued

Jul 22, 2019

Abate by

Dec 4, 2019

Penalty

Initial $5,635 · Current $3,945 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams (P&ID) were not accurate and did not represent equipment that was existing and was part of the process.  a) In the chlorine storage room at 500 Fortune Boulevard Milford, MA: On or about January 31, 2019, the employer's P&ID for their etching regeneration process was not accurate in that both one ton chlorine cylinders were shown to be connected to the process.  b)  In the chlorine storage room at 500 Fortune Boulevard Milford, MA: On or about January 31, 2019, the employer's P&ID for their etching regeneration process was not accurate in that multiple "x" markings were used to represent valves which was not explained in the legend.  c) In the production/etching area at 500 Fortune Boulevard Milford, MA: On or about January 31, 2019, the employer's P&ID of the chlorine feed system to etchers did not contain all of the components, valves and tubing associated with each etcher.  The lack of detail on the P&ID can expose operators and other employees to chlorine during normal and emergency operations.

Issued

Jul 22, 2019

Abate by

Dec 4, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): Information pertaining to the equipment in the process did not include relief system design and design basis:  In the chlorine room at 500 Fortune Boulevard Milford, MA: On or about January 25, 2019, the employer's process safety information (PSI) did not include the chlorine relief system design basis.  The process hazard assessment revalidation document, dated November 2018, does not include specific information on the relief system design and design basis.

Issued

Jul 22, 2019

Abate by

Dec 4, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F): Information pertaining to the equipment in the process did not include design codes and standards that were employed.  In the chlorine shed and etching area at 500 Fortune Boulevard Milford, MA: On or about January 31, 2019, the process safety information (PSI) did not include the design codes and standards employed during the compilation of the information.  The PSI section of the November 2018 process hazard analysis document (PHA) mentions the Chlorine Institute but does not identify which specific CI pamphlet(s) were used during the compilation of the PSI.

Issued

Jul 22, 2019

Abate by

Dec 4, 2019

Penalty

Initial $5,635 · Current $3,945 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment:  The employer failed to establish and implement written procedures to inspect, test and maintain the mechanical integrity of the schedule 80 piping system located between the pressure regulators and etcher isolation valves in the chlorine shed and etching/production room/area.

Issued

Jul 22, 2019

Abate by

Dec 4, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(j)(4)(ii): 29 CFR 1910.119(j)(4)(ii): Inspections and testing procedures performed on process equipment to maintain its mechanical integrity did not follow recognized and generally accepted good engineering practices (RAGAGEP):  Location: chlorine shed and production area: On or about January 31, 2019, the employer had not performed inspections and testing on process equipment including, but not limited to the schedule 80 PVC piping between the pressure regulators and etchers, Advantage ITT model A206 valves and Tekno model CAV-06 valves located throughout piping distribution system.  RAGAGEPs available for process piping and valves include, but are not limited to The Chlorine Institute pamphlet 6, Piping Systems for Dry Chlorine, Edition 16, March 2013, and American Standard Test Method (ASTM) D1784, Standard Specification for Rigid Poly(Vinyl Chloride) (PVC) Compounds and Chlorinated Poly(Vinyl Chloride) (CPVC) Compounds.

Issued

Jul 22, 2019

Abate by

Dec 4, 2019

Penalty

Initial $5,636 · Current $3,945 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(f)(1): The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process.   The production area at 500 Fortune Boulevard Milford, MA: On or about May 10, 2019, the employer did not develop and implement written operating procedures for etcher operators to follow during normal operations and emergency shutdown of the chlorine feed system and associated process equipment.  Operators, maintenance and other employees are potentially exposed to chlorine hazards from the lack of written procedures.

Issued

Jul 22, 2019

Abate by

Dec 4, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(o)(5): The employer did not retain the two (2) most recent compliance audit reports.  In the facility at 500 Fortune Boulevard Milford, MA: On or about January 31, 2019, the employer did not retain the last two most recent compliance audit reports.   The employer did retain the most recent report dated October 2015, but the previous compliance audit report was not located and available during the inspection.