OSHA Inspection: S. C. JOHNSON & SON, INC.

Issued

May 29, 2020

Abate by

Jul 16, 2020

Penalty

Initial $7,229 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i)(E): Process safety information pertaining to the technology of the process did not include a description of the specific employee impact during the qualitative evaluation  of the consequence of deviations    (a) On or about February 20, 2020, the Process Hazard Analysis (PHA) and operating procedures for the Acetone System developed by the employer did not qualitatively assess the range of the possible safety and health consequences of deviations on employees in the workplace. The potential cause-consequence pairs identified in the Hazard and Operability (HAZOP) Study for the PHA nor the consequences of deviations in the operating procedures do not discuss the possible number of employees affected by process deviations, the possible severity of injuries, or an evaluation of the potential for other employees to be affected by potential deviations in the process. This exposes chemical process operators of the Acetone System to fire, explosion, and chemical contact hazards while present in the production environment.    (b) On or about December 5, 2019, the PHA and the operating procedures for the Liquified Petroleum Gas (LPG) System developed by the employer did not qualitatively assess the range of the possible safety and health consequences of deviations on employees in the workplace. The potential cause-consequence pairs identified in the Hazard and Operability (HAZOP) Study for the PHA and the consequences of deviations in the operating procedures do not discuss the possible number of employees affected by process deviations, the possible severity of injuries, or an evaluation of the potential for other employees to be affected by potential deviations in the process. This exposes chemical process operators of the LPG system to fire, explosion, and chemical contact hazards while present in the production environment.    (c) On or about December 5, 2019, the PHA for the Liquified Petroleum Gas (LPG) Railcar Delivery System developed by the employer did not qualitatively assess the range of the possible safety and health consequences of deviations on employees in the workplace. The potential cause-consequence pairs identified in the Hazard and Operability (HAZOP) Study for the PHA did not discuss the possible number of employees affected by process deviations, the possible severity of injuries, or an evaluation of the potential for other employees to be affected by potential deviations in the process. This exposes chemical process operators of the LPG Railcar Delivery system to fire, explosion, and chemical hazards while present in the production environment.    (d) On or about December 5, 2019, the PHA Ethanol System developed by the employer did not qualitatively assess the range of the possible safety and health consequences of deviations on employees in the workplace. The potential cause-consequence pairs identified in the Hazard and Operability (HAZOP) Study for the PHA nor the consequences of deviations in the operating procedures do not discuss the possible number of employees affected by process deviations, the possible severity of injuries, or an evaluation of the potential for other employees to be affected by potential deviations in the process. This exposes chemical process operators of the Ethanol System to fire, explosion, and chemical contact hazards while present in the production environment.    (e) On or about December 5, 2019, the PHA  for the Isopropanol System developed by the employer did not qualitatively assess the range of the possible safety and health consequences of deviations on employees in the workplace. The potential cause-consequence pairs identified in the Hazard and Operability (HAZOP) Study for the PHA nor the consequences of deviations in the operating procedures do not discuss the possible number of employees affected by process deviations, the possible severity of injuries, or an evaluation of the potential for other employees to be affected by potential deviations in the process. This exposes chemical process operators of the Isopropanol System to fire, explosion, and chemical contact hazards while present in the production environment.    (f) On or about December 5, 2019, the PHA for the Isopentane System developed by the employer did not qualitatively assess the range of the possible safety and health consequences of deviations on employees in the workplace. The potential cause-consequence pairs identified in the Hazard and Operability (HAZOP) Study for the PHA nor the consequences of deviations in the operating procedures do not discuss the possible number of employees affected by process deviations, the possible severity of injuries, or an evaluation of the potential for other employees to be affected by potential deviations in the process. This exposes chemical process operators of the Isopentane System to fire, explosion, and chemical contact hazards while present in the production environment.    (g) On or about December 5, 2019, the PHA for the Naphtha System developed by the employer did not qualitatively assess the range of the possible safety and health consequences of deviations on employees in the workplace. The potential cause-consequence pairs identified in the Hazard and Operability (HAZOP) Study for the PHA did not discuss the possible number of employees affected by process deviations, the possible severity of injuries, or an evaluation of the potential for other employees to be affected by potential deviations in the process. This exposes chemical process operators of the Naphtha System to fire, explosion, and chemical contact hazards while present in the production environment.

Issued

May 29, 2020

Abate by

Jul 1, 2020

Penalty

Initial $4,337 · Current $4,337

General-duty citation text

29 CFR 1910.119(m)(5): The employer shall establish a system to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions shall be documented.    (a) On or about December 5, 2019, the employer did not promptly address and resolve incident report findings, in-that recommendations and findings that were determined to be an appropriate resolution on September 30, 2019, regarding an incident involving the release of Liquified Petroleum Gas (LPG) on September 20, 2019. The recommendations that had been made during the incident investigation were not incorporated into normal shutdown procedures or emergency shutdown procedures by May 26, 2020. Although stickers were placed on the electrical boxes for the power system advising employees of the possibility of LPG releases when the power was disconnected, no guidance was provided as part of the operating procedures as to what thresholds should be used, or factors to consider when deciding if overriding the air line shutdown is required in order to prevent the hydrostatic expansion of LPG in the line and subsequent release.

Issued

May 29, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams did not include information that provided specific identification of equipment that is part of the process.  (a) On or about February 11, 2020, inspection of Acetone process in Building 51, identified that P&IDs did not reflect current piping configuration within the Roach Bait room (R.B. Room). Pipe number P-710 and pipe line 374 were interconnected by stainless steel pipe section.  The P&ID reflected pipe P-710 and pipe line 374 terminated with a hand valve quick connection point.

Issued

May 29, 2020

Abate by

Jul 16, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(c)(4)(ii)(C): The energy control procedure did not clearly and specifically outline the steps for placement, removal and transfer of lockout devices or tagout devices and the responsibility for them.    (a) On or about December 5, 2019, in building 63, for the work of removing a blind for a condensate line, the process break permit (Pre-Job #13046) did not specify placement, removal and/or transfer location of isolation/lockout devices.    (b) On or about January 8, 2020, in building 63, for the work of connecting pipe to peroxide piping to T-10004, the process break permit (Pre-Job # 13003), did not specify placement, removal and/or transfer location of isolation/lockout devices.