OSHA Inspection: FULLER INDUSTRIES LLC.

Issued

Apr 6, 2021

Abate by

May 21, 2021

Penalty

Initial $13,516 · Current $7,434 Reduced

General-duty citation text

29 CFR 1910.22(d)(1): The employer did not ensure that walking-working surfaces are inspected, regularly and as necessary, and maintained in a safe condition  On or about October 14, 2020, the employer is failing to protect employees from slip and fall hazards.  The air filtration system in the Aerosol Hydrocarbon Room (Gas House) leaks product residue onto the floor leaving a slippery, wet surface where the operator walks. The operator is in the area greasing the filler and the pumps before each run.

Issued

Apr 6, 2021

Abate by

Sep 21, 2021

Penalty

Initial $13,516 · Current $7,434 Reduced

General-duty citation text

29 CFR  1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process.  On or about October 14, 2020, the employer's process hazard analysis (PHA) failed to identify and evaluate the hazards involved in the process associated with the "not in service" isobutane manifold system. In particular, the flange was missing bolts and, valves were tagged "not in use" but they did not alert the operator of the potential for isobutane released upon opening. Employees are exposed to chemical hazards associated with potential isobutane release.

Issued

Apr 6, 2021

Abate by

May 21, 2021

Penalty

Initial $13,516 · Current $7,434 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not address human factors.  On or about October 14, 2020, the employer's process hazard analysis (PHA) failed to identify and evaluate the hazards associated with the aerosol filling process in the tank farm and the gashouse. The employees operate the aerosol line in the gashouse and open valves at the tank farm to bring flammables to the gashouse. The PHA failed to address human factors such as mislabeling of equipment and piping which could lead to a situation where employees responsible for operating or maintaining the process could be confused and open/close incorrect valve, exposing employees to fire and explosion hazards from the release of flammable liquids and gases in aerosol filling operations.

Issued

Apr 6, 2021

Abate by

May 2, 2022

Penalty

Initial $13,516 · Current $7,434 Reduced

General-duty citation text

29 CFR  1910.119(f)(1)(i):  The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements:  (I) Steps for each operating phase:   [A] Initial startup  [B] Normal operations  [C] Temporary operations  [D] Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner  [E] Emergency operations  [F] Normal shutdown  [G] Startup following a turnaround, or after an emergency shutdown   On or about October 14, 2020, the employer's written operating procedures were inaccurate in the following instances:  a) The operating procedures to move propellant from the tank farm into the gashouse had instructions to open globe valves for the north pump skid, but the pump skid has ball valves and not globe valves.   b) The operating procedures for moving aerosol to the gas house and for operating the gas house equipment did not address emergency shutdown, conditions under which emergency shutdown is required, or assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner.  This exposed employees to fire and explosion hazards from the release of flammable liquids and gases in aerosol filling operations.

Issued

Apr 6, 2021

Abate by

Sep 21, 2021

Penalty

Initial $13,516 · Current $7,434 Reduced

General-duty citation text

29 CFR 1910.119(i)(1): Pre-startup safety review was not performed when modifications to existing facilities significant enough to require a change in the process safety information were made:  On or about October 14, 2020, the employer failed to conduct a pre-startup safety review before introducing highly hazardous chemicals into the modified process, adding a new pressure vessel to the existing aerosol tank farm, relocating the north pump skid that used to run Isobutane and AB-46, rearranging piping in north pump skid to run isobutane only, and rearranging piping that ran AB-46 to the north pump skid was rearranged to run from the south pump along with propane and installed modified valves.

Issued

Apr 6, 2021

Abate by

Sep 21, 2021

Penalty

Initial $13,516 · Current $7,434 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not implement procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process.   On or about October 14, 2020, the employer failed to implement their management of change procedures when they added new piping and a new pressure vessel for AB-46 in the tank farm.  In particular, the employer did not address the following as part of its management of change procedures:   a) Changes in valve types for the north pump skid.   b) Evaluation of relevant information about safety and health considerations for the proposed changes.   c) Information regarding the technical basis for the proposed changes such as the installation of new pipes and materials of construction.   d) Updates made to the process were reflected in the process safety information such as changes in pipe size.   This exposed employees to fire and explosion hazards from the release of flammable liquids and gases in aerosol filling operations.

Issued

Apr 6, 2021

Abate by

Sep 21, 2021

Penalty

Initial $13,516 · Current $7,434 Reduced

General-duty citation text

29 CFR  1910.119(g)(3): The employer shall ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The employer shall prepare a record that contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.  On or about October 14, 2020, the employer failed to ascertain that re-training was provided for employees involved in operating or maintaining the newly assigned process.  In particular, the employer did not prepare a record that contained the identity of the employee, the date of training, and the means used to verify that the employee understood the training after the installation of a new pressure vessel and rearrangement of the pumps skids and pipes in the tank farm.   The employer failed to record that maintenance personnel and operators had been trained in an overview of the process and that the operating procedures as specified in paragraph (f) of this section.   This exposed employees to fire and explosion hazards from the release of flammable liquids and gases in aerosol filling operations.

Issued

Apr 6, 2021

Abate by

Sep 21, 2021

Penalty

Initial $13,516 · Current $7,434 Reduced

General-duty citation text

29 CFR  1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process.  On or about October 14, 2020, the employer failed to develop accurate piping and instrument diagrams (P&IDs) and did not represent the equipment in the aerosol filling process. The P&IDs were mislabeled in that tag numbers of equipment did not match the P&ID legends for the equipment in the tank farm, the gashouse, and the manifold system the following instances:  a ) The equipment identified in the tank farm P&ID and legend as numbers 4b, 11, 16, 25, 41, and 42 are not tagged.  The P&ID and the legend use a tagging system with numbers to identify the equipment.  b) A gauge and a valve are tagged with the same number (29) in the tank farm.   c) Two valves were tagged with the same number (30) in the tank farm.  d) Valve number 9 of the north pump skid is identified in the P&ID as an electrical switch but the north pump skid has a valve tagged with the number 9.    e) The tags on the north pump skid, the aerosol line, and the manifold did not match the legend and the P&IDs.    f) Valve number 32 of the tank farm is a shut-off for tank number 6, which is a tank that contains isobutane, and it connects to the north pump skid. The P&ID shows valve number 32 as an emergency pop-off auto valve located on top of tank 7, which is a propane tank.   g) P&IDs do not include pipe size or length.  h) The north pump skid P&ID and legend indicate that tag number 17 is a 2" XH Nipple- Close, but there is a ball valve tagged number 17 instead.  i) The valve types was inaccurate in the P&IDs for the north pump skid. The legend indicated that there were globe-type valves installed in the system but the valves were ball valves.   j) The P&IDs and legend indicated that valve number 17 is a valve to tank 12 but the valve is not tagged. A valve tagged number 17 was found on the north pump skid.  k) The pump skid P&ID and legend indicated that tag number 10 is a fisher 2" globe valve but there was a ball valve that was tagged number 9 in the same place and no valves tagged number 10.  This exposed employees to fire and explosion hazards from the release of flammable liquids and gases in aerosol filling operations.

Issued

Apr 6, 2021

Abate by

May 21, 2021

Penalty

Initial $11,586 · Current $6,372 Reduced

General-duty citation text

29 CFR  1910.1200(f)(6): Except as provided in paragraphs (f)(7) and (f)(8) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged, or marked.   On or about October 14, 2020, the employer failed to protect employees from chemical hazards. The operator used five secondary containers of isopropanol, in the Aerosol Hydrocarbon Room in the Gas House that were not labeled. The operator uses isopropanol to help prevent the gasser heads from freezing and for cleaning purposes.

Issued

Apr 6, 2021

Abate by

May 2, 2022

Penalty

Initial $27,033 · Current $14,868 Reduced

General-duty citation text

29 CFR  1910.119(j)(2): The employer did not implement written procedures to maintain the on-going integrity of process equipment.  29 CFR  1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment.  On or about October 14, 2020, the employer failed to ensure that adequate written procedures for inspecting and testing emergency shutoff valves were established to maintain the on-going integrity of process equipment in the covered process.  In particular, the employer's written procedures did not include the emergency shutoff valve manufacturer's recommended inspection, testing, and preventative maintenance test tasks and methods, frequency of test intervals, acceptance criteria for test results, and steps for recognizing, correcting, and repairing equipment deficiencies to maintain the integrity of the process equipment.   Fuller Industries, LLC, was previously cited for a violation of this occupational safety and health standard or its equivalent standard 119.119(j)(2), which was contained in OSHA inspection number 1209600, citation number 1, item number 4a and was affirmed as a final order on July 26, 2017, with respect to a workplace located at 15 SW 40 Ave. Great Bend, KS 67530.

Issued

Apr 6, 2021

Abate by

May 2, 2022

Penalty

Initial $27,033 · Current $14,868 Reduced

General-duty citation text

29 CFR  1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment.  On or about October 14, 2020, the employer failed to test and inspect process equipment such as emergency shut-off valves according to the manufacturer's recommendations and good engineering practices. The emergency shut-off valves are located in the lines associated with the propane and AB-46 tanks. This exposed employees to fire and explosion hazards from the release of flammable liquids and gases in the tank farm and the aerosol line operations.  Fuller Industries, LLC, was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.119(J)(4)(i), which was contained in OSHA inspection number 1209600, citation number 1, item number 4/b and was affirmed as a final order on July 26, 2017, concerning a workplace located at 15 SW 40 Ave. Great Bend, KS 67530.

Issued

Apr 6, 2021

Abate by

Sep 21, 2021

Penalty

Initial $27,033 · Current $14,868 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.  On or about October 14, 2020, the employer failed to certify that they evaluated compliance with the provisions of 29 CFR 1910.119 at least every three years for the aerosol system. The last certification was on February 14, 2017.  By not evaluating compliance, the employees are exposed to ongoing fire and explosion hazards from the release of flammable liquids and gases in aerosol filling operations.   Fuller  Industries, LLC, was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.119(o)(1) previously cited standard), which was contained in OSHA inspection number 1209600, citation number 1, item number 6 and was affirmed as a final order on July 26, 2017, with respect to a workplace located at 15 SW 40 Ave. Great Bend, KS 67530.

Issued

Apr 6, 2021

Abate by

Sep 21, 2021

Penalty

Initial $1,084 · Current $596 Reduced

General-duty citation text

29 CFR  1910.147(c)(6)(ii): The employer did not certify that periodic inspections of the energy control procedures had been performed:  On or about October 14, 2020, the employer failed to protect employees from struck-by amputation and chemical hazards from the unexpected start-up of equipment.  The employer did not certify that periodic evaluations of the lockout/tag-out procedures had been conducted.