OSHA Inspection: BAE SYSTEMS ORDNANCE SYSTEMS, INC.

Issued

May 16, 2022

Abate by

Aug 19, 2022

Penalty

Initial $10,360 · Current $6,734 Reduced

Hazardous substances E200

General-duty citation text

29 CFR  1910.22(a)(1):All places of employment, passageways, storerooms, and service rooms were not kept clean and orderly and in a sanitary condition:  a)	Nitrator Process, Fourth Floor: On 11/18/21, and times prior, the employee(s) were exposed to fire and explosion hazards from the accumulation of combustible cellulose dust on the walls, pipes, equipment surfaces, and windowsills of the cellulose processing operation.

Issued

May 16, 2022

Abate by

Aug 19, 2022

Penalty

Initial $14,502 · Current $14,502

General-duty citation text

1910.119(e)(6): The employer did not update and revalidate the requirements in paragraph (e)(4) of this section at least every five years, to assure that the process hazard analysis is consistent with the current process:  (a) Nitration Process, Building 3045: On December 7, 2021, and times prior, the employer has not conducted a process hazard analysis update or revalidation in the past 5 years. The last process hazard analysis was conducted in June 2016.

Issued

May 16, 2022

Abate by

Aug 19, 2022

Penalty

Initial $14,502 · Current $14,502

General-duty citation text

29 CFR  1910.119(j)(2): Written procedures to maintain the on-going integrity of process equipment have not been established:   (a) Nitration Process, Building 3045, On December 7, 2021, and times prior, the employer did not establish and implement written mechanical integrity procedures for inspecting, testing and preventive maintenance of pressurized heat exchangers used in the process.  Failure to establish inspection procedures for the heat exchanger could result in the failure of the heat exchanger causing a loss of cooling in the washing process, resulting result in a fire or fume off and employee exposure to an acid release.  (b)  Nitration Process, Building 3045, On December 7, 2021, and times prior, the employer did not establish and implement written mechanical integrity procedures for inspecting, testing and preventive maintenance of piping systems, including piping components such as valves associated with the heat exchangers and wash tanks used in the process. Failure to establish inspection procedures of the piping or valving associated with the wash tanks could result in failure of the piping or valves causing a loss of containment exposing employees to the nitrating acid resulting in serious illness of death.  (c)  Nitration Process, Building 3045, On December 7, 2021, and times prior, the employer did not establish and implement written mechanical integrity procedures for inspecting, testing and preventive maintenance of valves associated with the heat exchangers and wash tanks used in the process. Failure to establish inspection procedures of the valving associated with the wash tanks could result in failure of the piping or valves causing a loss of containment exposing employees to the nitrating acid resulting in serious illness of death.

Issued

May 16, 2022

Abate by

Aug 19, 2022

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:  (a) Nitration Process, Building 3045:  On December 7, 2021, and times prior, the employer did not inspect and test the pressurized heat exchangers used in the process. Failure to conduct inspections and tests on the heat exchanger could result in the failure of the heat exchanger causing a loss of cooling in the washing process, resulting result in a fire or fume off and employee exposure to an acid release.  (b) Nitration Process, Building 3045:  On December 7, 2021, and times prior, the employer did not inspect and test the  piping systems associated with the heat exchangers and wash tanks used in the process. Failure to conduct inspections and tests on the piping or valving associated with the wash tanks could result in failure of the piping  causing a loss of containment exposing employees to the nitrating acid resulting in serious illness of death.  (c) Nitration Process, Building 3045:  On December 7, 2021, and times prior, the employer did not inspect and test the valves associated with the heat exchangers and wash tanks used in the process. Failure to conduct inspections and tests on the piping or valving associated with the wash tanks could result in failure of the valves causing a loss of containment exposing employees to the nitrating acid resulting in serious illness of death.

Issued

May 16, 2022

Abate by

Aug 19, 2022

Penalty

Initial $14,502 · Current $9,326 Reduced

General-duty citation text

29 CFR 1910.119(m)(4)(ii): Incident investigation reports prepared at the conclusion of the investigation did not include the date when the incident investigation began:  (a) Nitration Process, Building 3045:  On December 7, 2021, and times prior to, the employer conducted an incident investigation following the failure of multiple heat exchanges in the process. The incident investigation report did contain the date on which the incident investigation began.

Issued

May 16, 2022

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 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:  (a) Nitration Process, Building 3045:  On December 7, 2021, and times prior, the employer had not certified compliance at least every three years. The last compliance audit was conducted in 2017. Failure to conduct a compliance audit could lead to the improper care the process equipment resulting in the loss of containment of nitric acid a in the system and employee exposure to nitric acid resulting in serious illness or death.

Issued

May 16, 2022

Abate by

Aug 19, 2022

Penalty

Initial $12,431 · Current $8,080 Reduced

Hazardous substances 15911912

General-duty citation text

29 CFR  1910.134(h)(2)(i):Respirators were not stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals:  a)	Chemical Grind - Facility 3524: On or around 11/17/21, an employee's half-face negative pressure respirator was observed being stored, outside of its protective bag, directly on a table with visible contamination of 2-NDPA.    b) Fourth Rolled Powder Area, Pre-Roll Process - Facility 9309-4:  On or around 11/18/21, an employee's half-face negative pressure respirator was stored, outside of it's protective bag, directly next to the employer as product containing nitroglycerin was being handled, measured, and poured.    c) Fourth Rolled Powder Area, Evenspeed Process: On or around 2/23/22, six respirators were found improperly stored in nitroglycerin and lead work areas.  Improper storage included the respirators being stored outside of their protective bag, face down on a contaminated surface, and/or with contaminated work gloves stored inside the respirator.

Issued

May 16, 2022

Abate by

Aug 19, 2022

Penalty

Initial $10,360 · Current $6,734 Reduced

General-duty citation text

29 CFR  1910.212(a)(1):Machine guarding was not provided to protect operator(s) and other employees from hazards created by in-going nip points, rotating parts, and/or flying chips and sparks:  a)	Nitrator Process, Fourth Floor: On 11/18/21, and times prior, the employee(s) were exposed to unguarded rotating parts, in the form of a gear systems with a displaced guard.

Issued

May 16, 2022

Abate by

Aug 19, 2022

Penalty

Initial $8,287 · Current $8,287

Hazardous substances 1591

General-duty citation text

29 CFR  1910.1025(f)(3)(i)(C):The employer did not provide HEPA filters for powered and non-powered air-purifying respirators:  Radford Army Ammunition Plant: On 2/25/22, and times prior, the employee(s) wore respiratory protection in the form of negative pressure full-face respirators with organic vapor cartridges and Powered Air Purifying Respirators (PAPRs) with organic vapor cartridges, while working with lead containing LC 12-15.  According to the SDS for LC 12-15, particle filters are the appropriate respiratory control.