OSHA Inspection: BCP INGREDIENTS, INC.

Issued

Oct 1, 2021

Abate by

Oct 28, 2021

Penalty

Initial $13,653 · Current $9,557 Reduced

General-duty citation text

29 CFR  1910.22(a)(1):The employer did not ensure that all places of employment, passageways, storerooms, service rooms, and walking-working surfaces were kept in a clean, orderly, and sanitary condition.  The employer is failing to protect employees from fire and explosion hazards.  This was most recently documented on April 14, 2021, at the worksite located at 299 Extension Street, Verona, Missouri.  The employer is not providing walking-working surfaces that are free of hazards such as accumulation of dry choline.  Dry choline, a combustible and explosive dust, was observed in building V-26 on elevated surfaces at a depth greater than 1.5 inches.

Issued

Oct 1, 2021

Abate by

Nov 15, 2021

Penalty

Initial $13,653 · Current $9,557 Reduced

General-duty citation text

29 CFR  1910.119(c)(1):The employer did not develop a written plan of action regarding the implementation of the employee participation required by this paragraph.  The employer is failing to protect employees from hazards related to exposures to hazardous chemicals.  This was most recently documented on April 14, 2021, at the worksite located at 299 Extension Street, Verona, Missouri.  The employer did not develop a written employee participation plan-of-action which includes information on how employees will be consulted on the development of all PSM standard elements.

Issued

Oct 1, 2021

Abate by

Nov 15, 2021

Penalty

Initial $13,653 · Current $9,557 Reduced

General-duty citation text

29 CFR  1910.119(d)(3)(i)(B): The employer did not include all equipment that was part of the process on piping and instrument diagrams.    The employer is failing to protect employees from hazards related to highly hazardous chemicals onsite.  This was most recently documented on April 14, 2021, at the worksite located at 299 Extension Street, Verona, Missouri.  The employer did not ensure that the Process Safety Information depicted on the Piping and Instrument Diagram was up-to-date and accurate.  A)  P&I Diagram V-31 TMA Bulk Storage Tank did not accurately represent the actual equipment installed on the unit in that unit V-31-PT01-TMA was not listed on the diagram.    B)  P&I Diagram V-31 TMA Bulk Storage Tank did not accurately represent the actual equipment installed on the unit in that unit V-31-AV08-TMA was not listed on the diagram.  C)  P&I Diagram Ethylene Oxide Unloading did not accurately represent the actual equipment installed on the unit in that the inlet valve to the unloading pump (#00509) was not listed on the diagram.    D)  P&I Diagram Ethylene Oxide Unloading did not accurately represent the actual equipment installed on the unit in that the discharge valve the unloading pump (#00505) was not listed on the diagram.  E)  P&I Diagram Ethylene Oxide Unloading (V34-EORAIL, V34-EO, V34-EOP) did not accurately represent the actual equipment installed on the unit in that the #1 inlet/outlet (Valve #00511) was not listed on the diagram.   The Ethylene Oxide Railcar Unloading standard operating procedure, Number B-400, Effective Date 12/31/19, 8.1.4 addresses the #1 inlet/outlet (Valve #00511).    F)  P&I Diagram Ethylene Oxide Unloading (V34-EORAIL, V34-EO, V34-EOP) did not accurately represent the actual equipment installed on the unit in that Valve #00510 was not listed on the diagram.  The Ethylene Oxide Railcar Unloading standard operating procedure, Number B-400, Effective Date 12/31/19, 8.1.5 addresses Valve #00510.

Issued

Oct 1, 2021

Abate by

Mar 15, 2022

Penalty

Initial $13,653 · Current $9,557 Reduced

General-duty citation text

29 CFR  1910.119(d)(3)(ii):The employer did not document that equipment complies with recognized and generally accepted good engineering practices.  The employer is failing to protect employees from exposure to toxic and or hazardous chemicals.  This was most recently documented on April 14, 2021, at the worksite located at 299 Extension Street, Verona, Missouri.  The employer did not follow recognized and generally accepted good engineering practices (RAGAGEP) per ASME A13.1.   The employer did not label piping containing ethylene oxide from the bulk storage tanks to the ethylene oxide repackaging process in V25 nor to the aqueous choline process.

Issued

Oct 1, 2021

Abate by

Sep 30, 2022

Penalty

Initial $13,653 · Current $9,557 Reduced

General-duty citation text

29 CFR  1910.119(j)(4)(i):The employer did not adequately perform inspection and tests on process equipment.  The employer is failing to protect employees from hazards related to hazardous chemicals such as but not limited to ethylene oxide.  This was most recently documented on April 14, 2021, at the worksite located at 299 Extension Street, Verona, Missouri, where the employer failed to adequately test and inspect process equipment in the following:   A)  Piping containing ethylene oxide from storage tank 1 and storage tank 2 to V25, EO repackaging and to Aqueous Choline was not inspected and tested.   B)  Pressure relief valves were not inspected and tested such as but not limited to 29 pressure relieving devices associated with the ethylene oxide process.

Issued

Oct 1, 2021

Abate by

Dec 1, 2021

Penalty

Initial $13,653 · Current $0 Reduced

General-duty citation text

29 CFR  1910.119(j)(4)(ii):Inspection and testing procedures did not follow recognized and generally accepted good engineering practices:  The employer is failing to protect employees from hazards of chemicals used daily.  This was most recently documented on April 14, 2021, at the worksite located at 299 Extension Street, Verona, Missouri.    The employer is failing to follow the recognized and generally accepted good engineering practices (RAGAGEP) such as API 570 - 2, 016 Piping Inspection Code:  In-Service Inspection, Rating, Repair, and Alteration of Piping Systems, Section 5.5 General Types of Inspection and Surveillance for inspection and testing of piping systems.  The employer did not inspect and test piping such as but not limited to those in V34 and in V25 containing ethylene oxide.    Section 6.3 Piping Inspection Planning.  The employer did not inspect and test piping for degradation that can affect process piping circuits such as but not limited to those in the ethylene oxide storage system and in V25 containing ethylene oxide.   Section 6.7.3 PRD Testing and Inspection Intervals for inspection and testing of relief devices.  The employer did not have the pressure relief devices such as but not limited to pressure relief valves tested and repaired by a repair organization experienced in pressure relieving device maintenance.    The employer is failing to follow the RAGAGEP such as API 576 -2017 Inspection of Pressure Relieving Devices, Section 6 Inspection and Testing for inspection and testing of relief devices.  The employer did not do internal inspections of the relief devices.    This condition exposed employees to potential ethylene oxide exposure in the instance of a over pressured vessel, result in loss of containment during normal operating conditions.  Corrosion causes loss of material thickness resulting in piping and relief devices being able to withstand less pressure without failing.

Issued

Oct 1, 2021

Abate by

Jan 3, 2022

Penalty

Initial $13,653 · Current $9,557 Reduced

General-duty citation text

29 CFR  1910.119(l)(4):Process safety information required by paragraph (d) of this section was not updated when a change covered by this paragraph resulted in a change in the process safety information.  The employer is failing to protect employees from hazards related to hazardous chemicals such as but not limited to ethylene oxide.  This was most recently documented on April 14, 2021, at the worksite located at 299 Extension Street, Verona, Missouri.  The process safety information was not updated when a change in the process was made.

Issued

Oct 1, 2021

Abate by

Jan 3, 2022

Penalty

Initial $13,653 · Current $0 Reduced

General-duty citation text

29 CFR  1910.119(l)(5): When a change covered by this paragraph resulted in a change in the operating procedures or practices required by paragraph (f) of this section, such procedures or practices were not updated accordingly.  The employer is failing to protect employees from hazards related to hazardous chemicals such as but not limited to ethylene oxide.  This was most recently documented on April 14, 2021, at the worksite located at 299 Extension Street, Verona, Missouri.  The employer did not update the operating procedures when a change in the process occurred.

Issued

Oct 1, 2021

Abate by

Nov 15, 2021

Penalty

Initial $13,653 · Current $9,557 Reduced

General-duty citation text

29 CFR  1910.119(n): The employer did not establish an emergency plan for the entire plant in accordance with the provisions of 29 CFR 1910.38:  The employer is failing to protect employees from injury or illness when responding to an emergency such as fire, flood or chemical release.  This was most recently documented on April 14, 2021, at the worksite located at 299 Extension Street, Verona, Missouri.    A)  The employer's emergency action plan did not ensure employees were prepared for emergency evacuations.  B)  The employer's emergency action plan did not include employees who were to remain to shut down critical processes in an orderly manner.  C)  The employer's emergency action plan did not include distinct signals for fire, flood or chemical release.  D)  The employer did not review emergency response procedures with employees  such that employees were not aware of how to respond to an incident such as fire, flood, or chemical release.

Issued

Oct 1, 2021

Abate by

Oct 28, 2021

Penalty

Initial $13,653 · Current $9,557 Reduced

General-duty citation text

1910.119(o)(1) The employer did not certify that they have evaluated compliance with the provisions of this section at least every three years:   The employer is failing to protect employees from hazards related to hazardous chemicals such as but not limited to ethylene oxide.  This was most recently documented on April 14, 2021, at the worksite located at 299 Extension Street, Verona, Missouri.   The employer has not retained that they are complying with the elements of Process Safety Management.

Issued

Oct 1, 2021

Abate by

Jan 3, 2022

Penalty

Initial $13,653 · Current $9,557 Reduced

General-duty citation text

29 CFR  1910.307(b):Documentation for areas designated as hazardous (classified) locations under the Class and Zone system and areas designated under the Class and Division system established after August 13, 2007 was not available to those authorized to design, install, inspect, maintain, or operate electric equipment at the location:  The employer is failing to protect employees from electrical shock and explosion hazards.  This was most recently documented on April 14, 2021, at the worksite located at 299 Extension Street, Verona, Missouri.  Hazardous locations where requirement for dust proof/tight electrical are unknown and a schematic diagram outlining the layout of the Class II wiring in the facility was not available.

Issued

Oct 1, 2021

Abate by

Aug 1, 2022

Penalty

Initial $13,653 · Current $9,557 Reduced

General-duty citation text

29 CFR  1910.307(c)(3):Equipment was not safe for the location in that it was not of a type and design that the employer demonstrated would provide protection from the hazards arising from the combustibility and flammability of vapors, liquids, gases, dusts, or fibers involved:    The employer is failing to protect employees from fire and or explosion hazards.   This was most recently documented on April 14, 2021, at the worksite located at 299 Extension Street, Verona, Missouri.  The employer had equipment that was not rated for a Class II location.  Building V26 on the dry choline side had dry choline accumulations greater than 1/8th of an inch.

Issued

Oct 1, 2021

Abate by

Oct 28, 2021

Penalty

Initial $13,653 · Current $9,557 Reduced

General-duty citation text

29 CFR  1910.1052(d)(2):The employer did not perform initial monitoring to determine each employee's exposure to methylene chloride:  The employer is failing to protect employees from hazards of chemicals used daily.  This was most recently documented on April 14, 2021, at the worksite located at 299 Extension Street, Verona, Missouri.  The employer did not perform initial monitoring  when using a product containing methylene chloride.