OSHA Inspection: PCI SYNTHESIS

Issued

Aug 7, 2020

Abate by

Jan 8, 2021

Penalty

Initial $10,390 · Current $6,500 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i)(D): Information concerning the technology of the process did not include safe upper and lower limits for such items as temperatures, pressures, flows or compositions:    (a) Location: 9 Opportunity Way, Newburyport, MA 01950    On or about 2/9/20, process safety information about the technology of the process did not include the following:        a) Process safety information regarding a step in the operating procedures does not address the relief of vacuum prior to           opening the PFN-2 handway for the taking of a sample of the product.        a) Process safety information regarding a step in the operating procedures does not address the introduction of nitrogen           gas prior to opening the PFN-2 handway for the taking of a sample of the product.

Issued

Aug 7, 2020

Abate by

Jan 8, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(2)(i)(E): Information concerning the technology of the process did not include an evaluation of the consequences of deviations, including those affecting the safety and health of employees:    (a) Location: 9 Opportunity Way, Newburyport, MA 01950    On or about 2/9/20, process safety information about the technology of the process did not include the following regarding consequences of deviations, including but not limited to the following instances:        a) Process safety information regarding a step in the operating procedures did not address the consequences of opening           the PFN-2 handway while the vessel was under vacuum, which could result into drawing foreign materials into the           vessel, resulting in an unanticipated reaction.        b) Process safety information regarding a step in the operating procedures did not address the consequences of           opening the PFN-2 handway while the vessel was under nitrogen blanket, which could result in foreign material            entering the vessel, resulting in an unanticipated reaction.

Issued

Aug 7, 2020

Abate by

Jan 8, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(A): Written operating procedures providing clear instruction for conducting operations in a covered process safely and consistently with process safety information addressing consequences of deviation from operating limits have not been developed:    (a) Location: 9 Opportunity Way, Newburyport, MA 01950    On or about 2/9/20, the employer did not establish written operating procedures that provided clear instruction on consequences of deviation from the following operations:        a) Written operating procedures did not address consequences of deviation for a step in the operating procedures,           where vacuum pressure must be relieved to open the handway in order to take a sample.        b) Written operating procedures did not address consequences of deviation for a step in the operating procedures,           where nitrogen pressure must be added in order to keep contaminants out of the vessel while taking a sample.

Issued

Aug 7, 2020

Abate by

Jan 8, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(ii)(B): Written operating procedures providing clear instruction for conducting operations in a covered process safely and consistently with process safety information addressing steps required to correct or avoid deviation from operating limits have not been developed:    (a) Location: 9 Opportunity Way, Newburyport, MA 01950    On or about 2/9/20, the employer did not establish written operating procedures that provided clear instruction on steps to correct or avoid deviation for the following operations:        a) Written operating procedures did not address steps to correct or avoid deviations for a step in the operating procedures,           where vacuum pressure must be relieved to open the handway in order to take a sample.            b) Written operating procedures did not address steps to correct or avoid deviation for a step in the operating procedures,            where nitrogen pressure must be added in order to keep contaminants out of the vessel while taking a sample.

Issued

Aug 7, 2020

Abate by

Jan 8, 2021

Penalty

Initial $10,390 · Current $6,500 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(E): Process safety information concerning the equipment of the process did not include ventilation system design:    (a) Location: 9 Opportunity Way, Newburyport, MA 01950    On or about 2/10/20, the employer did not have process safety information regarding the design of the ventilation system for the Dekon manufacturing process.

Issued

Aug 7, 2020

Abate by

Jan 8, 2021

Penalty

Initial $7,422 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(H): Process safety information pertaining to the equipment in the process did not include the safety systems (e.g., interlocks, detection , or suppression systems):    a) Location: 9 Opportunity Way, Newburyport, MA 01950    On or about 2/10/20, process safety information that pertained to safety systems including the fire suppression system for the manufacture of Dekon was not specific regarding the actual components and parameters under which the components will activate and suppress a fire, including but not limited to the following instances:        a) Fire/smoke detection and suppression systems         b) Fire alarm panel and master call box         c) Inert gas fire suppression systems             d) Wet sprinkler system         e) Pull stations

Issued

Aug 7, 2020

Abate by

Jan 8, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(iv): Written operating procedures providing clear instruction for conducting operations in a covered process safely and consistently with process safety information addressing safety systems and their functions have not been developed:    (a) Location: 9 Opportunity Way, Newburyport, MA 01950    On or about 2/10/20, the employer did not develop written operating procedures addressing safety systems to safely conduct chemical manufacturing, including, but not limited to the following instances:        a) Fire/smoke detection and suppression systems         b) Fire alarm panel and master call box         c) Inert gas fire suppression systems             d) Wet sprinkler system         e) Pull stations

Issued

Aug 7, 2020

Abate by

Jan 8, 2021

Penalty

Initial $10,390 · Current $6,500 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i): The process hazards analysis did not address the hazards of the process:    (a) Location: 9 Opportunity Way, Newburyport, MA 01950    On or about 2/9/20, the process hazard analysis did not address the following hazards of the Dekon manufacturing process.         a) The process hazard analysis did not evaluate for potential hazards from breaking the vacuum of the vessel in order to           open the handway into PFN2 in order to take a sample. By not analyzing this step in the process, the employer did not           assess the hazards that the introduction of air or other contaminants presents.         b) The process hazard analysis did not evaluate for potential hazards from inerting the vessel with nitrogen prior to           opening the manway to take a sample. By not analyzing this step in the process, the employer did not assess the           hazards of opening the manway under a zero or positive pressure environment.

Issued

Aug 7, 2020

Abate by

Jan 8, 2021

Penalty

Initial $7,422 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(B): Written operating procedures providing clear instruction for conducting operations in a covered process safely and consistently with process safety information addressing safety and health considerations such as precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment have not been implemented:      (a) Location: 9 Opportunity Way, Newburyport, MA 01950    On or about 2/9/20, written operating procedures did not address the ability of employee clothing to prevent burns in the event of flash fires. The manufacture of Dekon has flammable solvents that can ignite, and employees may be burned if there are deviations from the operating procedures.

Issued

Aug 7, 2020

Abate by

Jan 8, 2021

Penalty

Initial $7,422 · Current $6,500 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(ii): The process hazard analysis did not address the identification of any previous incident which has a likely potential for catastrophic consequences in the workplace.    a) Location:  9 Opportunity Way, Newburyport, MA 01950    On or about 2/10/20, the process hazard analysis did not address three previous incidents of fires that occurred related to the Dekon manufacturing process. The incidents are as follows;        a) The process hazard analysis did not address an incident that occurred on 12/07/12, where a fire occurred during the           process where the product ignited during the process, resulting in a fire.          b) The process hazard analysis did not address an incident that occurred on 12/16/16, where outside air was able to enter          a funnel, resulting in an explosion.         c) The process hazard analysis did not address an incident that occurred on 2/9/19, where personal protective equipment          was placed in an incorrect container, resulting in a fire.