OSHA Inspection: SCHIRM USA INC.

Issued

Apr 10, 2023

Abate by

May 30, 2023

Penalty

Initial $6,696 · Current $4,018 Reduced

General-duty citation text

29 CFR 1910.39(b): A fire prevention plan was not written, be kept in the workplace, and be made available to employees for review.  On or about 11/10/2022, at the Schirm facility located in Ennis Texas, employees were exposed to hazards of fire when the employer did not have a written fire prevention plan in the workplace.

Issued

Apr 10, 2023

Abate by

May 30, 2023

Penalty

Initial $15,625 · Current $9,375 Reduced

General-duty citation text

29 CFR 1910.119(d): The employer did not complete a compilation of written process safety information pertaining to the equipment in the process that consisted of at least the information specified in sections (d)(1)(i) through (d)(3)(i)(H).  On or about 11/10/2022, at the Schirm facility located in Ennis Texas, employees were exposed to chemical release hazards when the employer did not complete a compilation of written process safety information such as manufacturer's data report for pressure vessels including but not limited to:  a). The employer did not document manufacturer's data reports for Isopropylamine (IPA) tank. b). The employer did not document manufacturer's data reports for Reactor R-1. c). The employer did not document manufacturer's data reports for Reactor R-2.

Issued

Apr 10, 2023

Abate by

May 30, 2023

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams (P&IDs) were not accurate.  On or about 11/10/2022, at the Schirm facility located in Ennis Texas, employees exposed to chemical release hazards when the employer did not accurately document piping and instrument diagrams for process safety management cover process including but not limited to:  a.)	P&IDs do not include a salt tank (Product tank), liquid Nitrogen tank and their associated piping.  b.)	P&IDs do not indicate pipe sizes, pipe materials, P&ID assigned numbers, origin and designation of piping and legends of process equipment and instruments.  c.)	Isopropylamine (IPA) tank P&ID does not show 2 pressure relief valves (PRVs) on the top, block valves from discharge of pumps (P-01for loading from a tanker truck to IPA tank, P-02 &03 for feeding IPA from the IPA tank to reactors R-1&R-2), two separate piping from the IPA tank to the IPA pumps (P-02 &03), valve tag (or Number) on Nitrogen line, flexible hoses and connection mechanism from a tanker truck to the loading pump (P-01), flexible piping from the IPA tank to IPA pumps (P-02-&03).  d.)	P&IDs of Reactors R1& R2 or IPA tank do not show 2 pressure relief valves on IPA lines from the IPA pumps (P-02&03) to reactors (R-1&2).

Issued

Apr 10, 2023

Abate by

May 30, 2023

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): Process safety information (PSI) pertaining to the equipment in the process did not include relief system design and design basis.  On or about 11/10/2022, at the Schirm facility located in Ennis Texas, employees were exposed to chemicals release hazards when the employer did not document relief system design and design basis for pressure relieve valves including but not limited to:  a)	The employer did not document relief system design and design basis for two (2) pressure relieve valves on the top of isopropylamine (IPA) tank.    b)	The employer did not document relief system design and design basis for the pressure relieve valve PRV-01 on the top of Reactor R-1.  c)	The employer did not document relief system design and design basis for the pressure relieve valve PRV-02 on the top of Reactor R-2.  d)	The employer did not document relief system design and design basis for a pressure relieve on a discharge pipe of the isopropylamine pump P-02.  e)	 The employer did not document relief system design and design basis for a pressure relieve on a discharge pipe of the isopropylamine pump P-03.

Issued

Apr 10, 2023

Abate by

May 30, 2023

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.119(d)(3)(i)(F):Process safety information (PSI) pertaining to the equipment in the process did not include design codes and standards employed. On or about 11/10/2022, at the Schirm facility located in Ennis Texas, employees were exposed to chemicals release hazards when the employer did not document design codes and standards employed for process equipment.

Issued

Apr 10, 2023

Abate by

May 30, 2023

Penalty

Initial $15,625 · Current $9,375 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility sitting.  On or about 11/10/2022, at the Schirm facility located in Ennis Texas, the process hazard analysis (PHA) did not properly address facility sitting. This condition potentially exposed employees to fire and explosion.

Issued

Apr 10, 2023

Abate by

May 30, 2023

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not address human factors.  On or about 11/10/2022, at the Schirm facility located in Ennis Texas, 2012 and 2019 process hazard analysis (PHAs) did not address did not human factors. This condition potentially exposed employees to chemical release hazards.

Issued

Apr 10, 2023

Abate by

May 30, 2023

Penalty

Initial $0 · Current $0

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.  On or about 11/10/2022, at the Schirm facility located in Ennis Texas, the 2019 process hazard analysis (PHA) 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.

Issued

Apr 10, 2023

Abate by

May 30, 2023

Penalty

Initial $6,696 · Current $4,018 Reduced

General-duty citation text

29 CFR 1910.119(f)(3): The operating procedures were not reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer did not certify annually that these operating procedures were current and accurate.   On or about 11/10/2022, at the Schirm facility located in Ennis Texas, employees were exposed to chemical release hazards when the employer did not annually certify operating procedures to ensure that they are current and accurate. The inaccurate procedures include:  a.)	Normal and Temporary Operation Procedures for Reactor R-1 b.)	Normal and Temporary Operation Procedures for Reactor R-2

Issued

Apr 10, 2023

Abate by

May 30, 2023

Penalty

Initial $15,625 · Current $9,375 Reduced

General-duty citation text

29 CFR 1910.119(f)(4): The employer did not develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel.   Instance a.) On or about 11/10/2022, at the Schirm facility located in Ennis Texas, employees were exposed to chemical release hazards when the employer did not develop and implement safe work practices to provide for the control of hazards during operations such as control over entrance into a facility by employees, contractor employees, and other support personnel.   Instance b.) On or about 11/10/2022, at the Schirm facility located in Ennis Texas, employees were exposed to chemical release hazards when the employer did not develop and implement safe work practices to provide for the control of hazards during operations such as line breaking procedures or opening process equipment or piping.

Issued

Apr 10, 2023

Abate by

Jul 13, 2023

Penalty

Initial $15,625 · Current $9,375 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment.   On or about 11/10/2022, at the Schirm facility located in Ennis Texas, employees were exposed to chemical release hazards when the employer did not ensure that written procedures for testing or inspecting of process equipment were established and implemented including but not limited to:  a)	Emergency stop buttons (E-Stops) for the process located inside and outside the control room and for the loading pump (P-01) located at a loading area. b)	Pressure vessels including isopropylamine (IPA) tank, Reactors R-1 and R-2. c)	Pressure relief valves (PRVs) including 2 PRVs on the IPA tank, a PRV on reactor R-1&R-2, 2 PRVs on discharge pipes from IPA pumps, P-02& P-03. d)	Level control switch high/alarms, LSH-01 & LSH-02  e)	Pressure transmitter PT-01. f)	Flow control valves, FV01-1on IPA line from pump P-02 to reactor R-1 and FV03-1 on process water line. g)	Flow controller, FIC 07-1, on a sulfuric acid line. h)	Piping system including isopropyl amine (IPA) lines from the IPA tank to reactors R-1 and R-2.

Issued

Apr 10, 2023

Abate by

Jul 13, 2023

Penalty

Initial $15,625 · Current $9,375 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 11/10/2022, at the Schirm facility located in Ennis Texas, employees were exposed to chemical release hazards when the employer did not perform inspection and testing on process equipment for the isopropylamine systems including but not limited to:  a.	Two pressure relief valves (PRVs) for the isopropylamine (IPA) tank b.	One PRV-01 for reactor R-1 c.	One PRV-02 for reactor R-2 d.	One PRV on a discharge pipe of the IPA pump P-02 e.	One PRV on discharge pipe of the IPA pump P-03 f.	Isopropylamine pipelines from IPA tank to pumps P-02 & P-03 g.	Isopropylamine pipelines from pumps P-02&03 to reactors R-1& R-2

Issued

Apr 10, 2023

Abate by

May 30, 2023

Penalty

Initial $6,696 · Current $4,018 Reduced

General-duty citation text

29 CFR 1910.119(n): The employer's emergency action plan did not include procedures for handling small releases:  On or about 11/10/2022, at the Schirm facility located in Ennis Texas, employees exposed to chemical release hazards when the employer did not include procedures for handling small releases such as isopropylamine (IPA) and nitrogen in the emergency action plan.

Issued

Apr 10, 2023

Abate by

May 30, 2023

Penalty

Initial $6,696 · Current $4,018 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not evaluate compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard were adequate and being followed.  On or about 11/10/2022, at the Schirm facility located in Ennis Texas, employees were exposed to chemicals release hazards when the employer did not conduct Process Safety Management (PSM) compliance audits for the Isopropylamine (IPA) process.

Issued

Apr 10, 2023

Abate by

May 30, 2023

Penalty

Initial $6,696 · Current $4,018 Reduced

General-duty citation text

29 CFR 1910.132(d)(1): The employer did not assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE).  On or about 11/10/2022, at the Schirm facility located in Ennis Texas, the employer did not assess the isopropylamine process area to determine flammable retardant clothes (FRC) were necessary to protect employees from flash fire hazards associated with the flammable liquid isopropylamine (IPA).

Issued

Apr 10, 2023

Abate by

May 30, 2023

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(g)(3): The employer did not ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The employer did not prepare a record which 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 11/10/2022, at the Schirm facility located in Ennis Texas, the employer did not prepare initial and refresher training records which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training regarding operating the isopropylamine (IPA) process.

Issued

Apr 10, 2023

Abate by

Jul 13, 2023

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(iv): The employer did not document the date of inspection, the name of the person performing the inspection, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection, and the results of the inspection for each piece of process equipment.  On or about 11/10/2022, at the Schirm facility located in Ennis Texas, the employer did not document each inspection and test that has been performed on process equipment including but not limited to:  a)	An emergency stop button (E-Stop) for shutting down the loading pump P-01 located at a loading area. b)	An emergency stop button (E-Stop) for shutting down the process located in the control room. c)	An emergency stop button (E-Stop) for shutting down the process located outside the control room. d)	Level control switch LSH-01 for Isopropylamine (IPA) tank. e)	Level control switch LSH 02-1for Reactor R1.