OSHA Inspection: HIGHLINE WARREN, LLC

Issued

Jan 20, 2023

Abate by

Oct 13, 2023

Penalty

Initial $11,162 · Current $7,813 Reduced

Hazardous substances 1660

General-duty citation text

29 CFR  1910.119(d)(1):  Process safety information pertaining to the hazards of the highly hazardous chemicals in the process did not consist of the elements specified in 29 CFR 1910.119 (d)(1)(i) through (vii):  165 Pioneer Dr, Leominster MA: On or about 8/3/22, the process safety information pertaining to methanol did not include toxicity information, thermal and chemical stability data, physical data, and permissible exposure limit (PEL).

Issued

Jan 20, 2023

Penalty

Initial $0 · Current $0

Hazardous substances 1660

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:  165 Pioneer Dr, Leominster MA: On or about 8/3/22, the piping and instrument diagrams were not current.  Two methanol pumps, located between the outdoor methanol storage tank and the blend-on-demand room, were not included in the piping and instrument diagrams, and the pumps had been installed in 2019.

Issued

Jan 20, 2023

Abate by

Apr 14, 2023

Penalty

Initial $11,162 · Current $0 Reduced

Hazardous substances 1660

General-duty citation text

29 CFR  1910.119(e)(3)(vii):  The process hazard analysis did not address a qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace:  165 Pioneer Dr, Leominster MA: On or about 8/3/22, Appendix A, the Process Hazard Review (PHR) Recommendation Table of the Draft PSM Program, the process hazard analysis (PHA) listed "reversible health effects," and did not address a qualitative evaluation of a range of the possible safety and health effects.

Issued

Jan 20, 2023

Abate by

Apr 14, 2023

Penalty

Initial $0 · Current $0

Hazardous substances 1660

General-duty citation text

29 CFR  1910.119(e)(5):  The employer did not establish a system to promptly address the PHA team's findings and recommendations:  165 Pioneer Dr, Leominster MA: On or about 8/3/22, some of the PHA team's findings and recommendations, in Appendix A, Process Hazard Review (PHR) Recommendation Table of Draft PSM Program, had not been promptly addressed, and the employer did not establish a system to do so.  The table did not identify a timeline for tracking and completion of recommendations.

Issued

Jan 20, 2023

Abate by

Jul 14, 2023

Penalty

Initial $11,162 · Current $7,813 Reduced

Hazardous substances 1660

General-duty citation text

29 CFR  1910.119(f)(1)(i)(D):  The employer did not develop and implement written operating procedures that provide clear instructions for 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:  165 Pioneer Dr, Leominster MA: On or about 8/3/22, the employer's procedure for emergency shutdown of the methanol system did not include the conditions under which emergency shutdown is required.

Issued

Jan 20, 2023

Abate by

Oct 13, 2023

Penalty

Initial $11,162 · Current $7,815 Reduced

Hazardous substances 1660

General-duty citation text

29 CFR  1910.119(j)(2):  The employer did not establish written procedures to maintain the on-going integrity of process equipment:   165 Pioneer Dr, Leominster MA: Blend-on-demand (BOD) room to filling:  (a)  Blend-on-demand room: On or about 8/3/22, the employer did not establish written procedures to maintain the on-going integrity of process equipment such as of pipes and valves and associated equipment such as ball valves and regulators.  Recognized and generally accepted good engineering practices (RAGAGEPs) are available for methanol piping such as, but not limited to, American Petroleum Institute (API) standards 570 Piping and Inspection Code, and 574 Inspection Practices for Piping System Components.  (b)  BOD 1 Manifold (methanol): On or about 8/3/22, the employer did not establish written procedures to maintain the on-going integrity of process equipment such as pipes and valves and associated equipment such as loop pumps, gear/lobe pump, and peristaltic pump.  RAGAGEPs are available for methanol piping such as, but not limited to, American Petroleum Institute (API) standards 570 Piping and Inspection Code, and 574 Inspection Practices for Piping System Components.

Issued

Jan 20, 2023

Abate by

Oct 13, 2023

Penalty

Initial $0 · Current $0

Hazardous substances 1660

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: Note:  This standard applies to pressure vessels and storage tanks; piping systems (including piping components and valves); relief and vent systems and devices; emergency shutdown systems; controls (including monitoring devices and sensors, alarms, and interlocks) and pumps, as referenced by sections (j)(1)-(j)(1)(vi) of this standard]:  165 Pioneer Dr, Leominster MA: Blend-on-demand (BOD) room to filling:  (a)  Blend-on-demand room: On or about 8/3/22, the employer did not document that the piping and valve inspection and testing procedures followed recognized and generally accepted good engineering practices to maintain the on-going integrity of all pipes and valves and associated equipment such as ball valves, regulators, and flange connections, shown on drawings PID-100 and PID-200 of the draft PSM report.  Recognized and generally accepted good engineering practices (RAGAGEPs) are available for methanol piping such as, but not limited to, American Petroleum Institute (API) standards 570 Piping and Inspection Code, and 574 Inspection Practices for Piping System Components.  (b)  BOD 1 Manifold (methanol): On or about 8/3/22, the employer did not document that the piping and valve inspection and testing procedures followed recognized and generally accepted good engineering practices to maintain the on-going integrity of all pipes and valves and associated equipment such as loop pumps, gear/lobe pump, and peristaltic pump, shown on drawing PID-300 of the draft PSM report.  RAGAGEPs are available for methanol piping such as, but not limited to, American Petroleum Institute (API) standards 570 Piping and Inspection Code, and 574 Inspection Practices for Piping System Components.

Issued

Jan 20, 2023

Abate by

Oct 13, 2023

Penalty

Initial $0 · Current $0

Hazardous substances 1660

General-duty citation text

29 CFR  1910.119(j)(4)(iii):  The frequency of inspections and tests of process equipment was not consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience:  165 Pioneer Dr, Leominster MA: Blend-on-demand (BOD) room to filling:  (a)  Blend-on-demand room: On or about 8/3/22, the frequency of inspections and tests was not consistent with good engineering practices to maintain the on-going integrity of all pipes and valves and associated equipment such as ball valves and regulators.  Recognized and generally accepted good engineering practices (RAGAGEPs) are available for methanol piping such as, but not limited to, American Petroleum Institute (API) standards 570 Piping and Inspection Code, and 574 Inspection Practices for Piping System Components.  API 570 contains Table 1, which specifies the frequency intervals for thickness and visual inspections.  (b)  BOD 1 Manifold (methanol): On or about 8/3/22, the frequency of inspections and tests was not consistent with good engineering practices to maintain the on-going integrity of all pipes and valves and associated equipment such as loop pumps, gear/lobe pump, and peristaltic pump.  RAGAGEPs are available for methanol piping such as, but not limited to, American Petroleum Institute (API) standards 570 Piping and Inspection Code, and 574 Inspection Practices for Piping System Components.  API 570 contains Table 1, which specifies the frequency intervals for thickness and visual inspections.

Issued

Jan 20, 2023

Penalty

Initial $11,162 · Current $7,813 Reduced

Hazardous substances 1660

General-duty citation text

29 CFR  1910.132(a):  Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers was not provided, used, and/or maintained.  165 Pioneer Dr, Leominster MA: On or about 8/3/22, employees working in the blend-on-demand room, and other hazardous (classified) locations/areas, were exposed to fire and explosion hazards while manufacturing windshield washer fluid using process safety management quantities of methanol, without fire resistant clothing.

Issued

Jan 20, 2023

Abate by

Jul 14, 2023

Penalty

Initial $0 · Current $0

Hazardous substances 1660

General-duty citation text

29 CFR  1910.132(d)(1)(i): The employer did not assess the workplace to determine if hazards were present, or were likely to be present, which necessitated the use of personal protective equipment (PPE):  165 Pioneer Dr, Leominster MA: On or about  8/3/22, the employer had not adequately assessed the workplace to determine when the use of fire resistant clothing was necessary.  Employees working in the blend-on-demand room, and other areas, were exposed to fire and explosion hazards while manufacturing windshield washer fluid using process safety management quantities of methanol.

Issued

Jan 20, 2023

Abate by

Apr 14, 2023

Penalty

Initial $11,162 · Current $7,813 Reduced

Hazardous substances 1660

General-duty citation text

29 CFR  1910.151(c):Where employees were exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use:  165 Pioneer Dr, Leominster MA: On or about 9/8/22, corrosive material such as, but not limited to, KATHON? CG/ICP, was being added to windshield washer fluid from an open bucket, and suitable facilities for quick drenching or flushing of the eyes and body were not provided within the methanol manifold work area for immediate emergency use.  The nearest eyewash was approximately 30-seconds away from the methanol manifold area where the corrosive material is used.

Issued

Jan 20, 2023

Abate by

Apr 14, 2023

Penalty

Initial $0 · Current $0

Hazardous substances 1660

General-duty citation text

29 CFR  1910.1200(f)(6)(ii): The employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with product identifier and words, pictures, symbols, or combination thereof, which provided at least general information regarding the hazards of the chemicals:  165 Pioneer Dr, Leominster MA: Methanol manifold area, outside of blend-on-demand (BOD) room : On or about 9/8/22, an open bucket of KATHON? CG/ICP, a corrosive material, which was being added to windshield washer fluid, was not labeled, tagged, or marked with the product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals.

Issued

Jan 20, 2023

Abate by

Dec 31, 2024

Penalty

Initial $11,162 · Current $7,813 Reduced

Hazardous substances 1660

General-duty citation text

29 CFR  1910.178(c)(2)(iv):  Power-operated industrial trucks designated as DY, EE, or EX were not used in locations where volatile flammable liquids or flammable gases were  handled, processed or used, but in which the hazardous liquids, vapors or gases will normally be confined within closed containers or closed systems from which they can escape only in case of accidental rupture or breakdown of such containers or systems, or in the case of abnormal operation of equipment; also in locations in which hazardous concentrations of gases or vapors are normally prevented by positive mechanical ventilation but which might become hazardous through failure or abnormal operation of the ventilating equipment; or in locations which are adjacent to Class I, Division 1 locations, and to which hazardous concentrations of gases or vapors might occasionally be communicated unless such communication is prevented by adequate positive-pressure ventilation from a source of clear air, and effective safeguards against ventilation failure are provided:  165 Pioneer Dr, Leominster MA: On or about 8/3/22, propane-powered LP industrial trucks were used in or adjacent to the filling area, which the employer had classified Class 1 Division 1, and were not designated as EE or EX.

Issued

Jan 20, 2023

Abate by

Jul 31, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 1660

General-duty citation text

29 CFR 1910.307(c)(1):  Equipment and associated wiring  not approved as intrinsically safe was permitted in a hazardous location (Classified) location for which it was not approved:  165 Pioneer Dr, Leominster MA: Filling area: (a)  On or about 8/3/22, electrical equipment such as, but not limited to, a floor fan not approved as intrinsically safe for use in a hazardous (classified)location was used in an area the employer had classified as Class 1, Division 1.  Area adjacent to blend-on-demand (BOD) room: (b)  On or about 8/3/22, electrical equipment such as, but not limited to, electrical panels, junction boxes, and outlets not approved as intrinsically safe for use in a hazardous (classified) location was used in an area the employer had classified as Class 1, Division 2.