OSHA Inspection: ENLIGHT GROUP II LLC

Issued

Jun 8, 2023

Abate by

Jul 31, 2023

Penalty

Initial $11,162 · Current $11,162

General-duty citation text

29 CFR  1910.119(d): the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.  On or about December 28, 2022, at the establishment located at 6311 W Custer Street Manitowoc, Wisconsin; the employer did not compile written process safety information pertaining to the hazards of manufacturing small arms ammunition.  All provisions of 29CFR 1910.119(d)(1) through (d)(3) must be covered in a process safety management of highly hazardous materials program.  Key elements include but are not limited to the following:          1.  Information pertaining to the hazards of the highly hazardous chemicals in the process.     2.  Information pertaining to the technology of the process.     3.  Information pertaining to the equipment in the process.

Issued

Jun 8, 2023

Abate by

Jul 31, 2023

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.119(e)(1):The employer shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. Employers shall determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process. The process hazard analysis shall be conducted as soon as possible, but not later than the following schedule:  On or about December 28, 2022, at the establishment located at 6311 W Custer Street Manitowoc, Wisconsin; the employer did not perform an adequate process hazard analysis to identify, evaluate, and control the hazards involved in the process of manufacturing small arms ammunition.  All provisions of 29CFR 1910.119(e)(1) through (e)(7) must be covered in a process hazard analysis.  Key elements include, but are not limited to, the following:          1.  One or more appropriate methodologies shall be used to determine and evaluate the hazards of the process being analyzed.     2.  The process hazard analysis shall address the hazards of the process, engineering and administrative controls, consequences of failure of engineering and administrative controls, facility siting, and human factors.     3.  The process hazards analysis shall be performed by a team with expertise in engineering and process operations, and at least one employee with experience and knowledge specific to the process.     4.  The employer shall establish a system to promptly address the team's findings.     5.  Be reviewed at least every five years.     6.  Process hazard analyses and updates shall be retained for each process covered by this section.

Issued

Jun 8, 2023

Abate by

Jul 31, 2023

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1): 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.  On or about December 28, 2022, at the establishment located at 6311 W Custer Street Manitowoc, Wisconsin; the employer did not develop written operating procedures for covered processes manufacturing small arms ammunition.  All provisions of 29CFR 1910.119(f)(1) through (f)(4) must be covered in a process safety management of highly hazardous materials program.  Key elements include, but are not limited to, the following:          1.  Steps for each operating phase of the process.     2.  Operating limits     3.  Safety and health considerations.     4.  Safety systems and their functions.

Issued

Jun 8, 2023

Abate by

Jul 31, 2023

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.119(l)(1):The employer shall establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.  On or about December 28, 2022, at the establishment located at 6311 W Custer Street Manitowoc, Wisconsin; the employer did not establish procedures to address the following considerations prior to implementing any change: a)  The technical basis for the proposed change; b)  Impact of change on safety and health; c)  Modifications to operating procedures; d)  Necessary time period for the change; and,  e)  Authorization requirements for the proposed change.

Issued

Jun 8, 2023

Abate by

Jul 10, 2023

Penalty

Initial $15,625 · Current $15,625

General-duty citation text

29 CFR 1910.147(c)(4)(ii): The procedures did not clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to, 29 CFR 1910.147(c)(4)(ii)(A-D).  On or about December 19, 2022, at the facility located at 6311 West Custer Street, Manitowoc, Wisconsin; the employer failed to ensure the control of hazardous energy procedure for the AmmoLoad Pistol machines did not properly identify all sources of hazardous energy such as, but not limited to, chemical energy.