OSHA Inspection: KIK INTERNATIONAL LLC

Issued

Dec 5, 2023

Abate by

Dec 22, 2023

Penalty

Initial $0 · Current $6,000

Hazardous substances 0640

General-duty citation text

29 CFR  1910.119(f)(1)(ii)(A): The employer did not develop and implement written operating procedures that addressed the consequences of deviations from the operating limits in the covered process:   a) Railcar Unloading Station, KIK Consumer Products, on or about June 26, 2023 - The employer did not develop written operating procedures that addressed consequences of deviations from chlorine railcar and piping temperature limits and chlorine flow limits in the written operating procedure NP-003 Normal Operating Procedure Chlorine Railcar Connection. Failure to develop operating procedures that address consequences of deviations from the operating limits in the covered process can expose employees to corrosive, toxic, and oxidizing hazards.  b) Bleach Plant Pad, KIK Consumer Products, on or about June 26, 2023 - The employer did not develop written operating procedures that addressed consequences of deviations from chlorine railcar and piping temperature limits and ORP limits in the written operating procedure NP-004 Normal Operating Procedure Powell Continuous Bleach Plant Automatic Startup. Failure to develop operating procedures that address consequences of deviations from the operating limits in the covered process can expose employees to corrosive, toxic, and oxidizing hazards.  c) Railcar Unloading Station, KIK Consumer Products, on or about June 26, 2023 - The employer did not develop written operating procedures that addressed consequences of deviations from chlorine railcar and piping temperature limits in the written operating procedure NP-001 Normal Operating Procedure Chlorine Railcar Disconnection. Failure to develop operating procedures that address consequences of deviations from the operating limits in the covered process can expose employees to corrosive, toxic, and oxidizing hazards.

Issued

Dec 5, 2023

Abate by

Dec 22, 2023

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR  1910.119(f)(1)(ii)(B): The employer did not develop and implement written operating procedures that provide clear instructions for steps required to correct or avoid deviation from the operating limits in the covered process:   a) Railcar Unloading Station, KIK Consumer Products, on or about June 26, 2023 - The employer did not develop written operating procedures that provide clear instructions for steps required to correct or avoid deviation from chlorine railcar and piping temperature limits in the written operating procedure NP-003 Normal Operating Procedure Chlorine Railcar Connection. Failure to develop operating procedures that provide clear instructions for steps required to correct or avoid deviation from the operating limits in the covered process can expose employees to corrosive, toxic, and oxidizing hazards.  b) Bleach Plant Pad, KIK Consumer Products, on or about June 26, 2023 - The employer did not develop written operating procedures that provide clear instructions for steps required to correct or avoid deviation from chlorine railcar and piping temperature limits in the written operating procedure NP-004 Normal Operating Procedure Powell Continuous Bleach Plant Automatic Startup. Failure to develop operating procedures that address consequences of deviations from the operating limits in the covered process can expose employees to corrosive, toxic, and oxidizing hazards.  c) Railcar Unloading Station, KIK Consumer Products, on or about June 26, 2023 - The employer did not develop written operating procedures  that provide clear instructions for steps required to correct or avoid deviation from chlorine railcar and piping temperature limits in the written operating procedure NP-001 Normal Operating Procedure Chlorine Railcar Disconnection. Failure to develop operating procedures that address consequences of deviations from the operating limits in the covered process can expose employees to corrosive, toxic, and oxidizing hazards.

Issued

Dec 5, 2023

Abate by

Dec 22, 2023

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR  1910.119(f)(1)(iii)(A): The employer did not develop and implement written operating procedures that provide properties of, and hazards presented by, the chemicals used in the process:  a) Railcar Unloading Station, KIK Consumer Products, on or about June 26, 2023 - The employer did not develop written operating procedures that provide properties of and hazards presented by chlorine in the written operating procedure NP-003 Normal Operating Procedure Chlorine Railcar Connection. Failure to develop operating procedures that provide properties of and hazards presented by chlorine can expose employees to corrosive, toxic, and oxidizing hazards.  b) Bleach Plant Pad, KIK Consumer Products, on or about June 26, 2023 - The employer did not develop written operating procedures that provide properties of and hazards presented by chlorine in the written operating procedure NP-004 Normal Operating Procedure Powell Continuous Bleach Plant Automatic Startup. Failure to develop operating procedures that provide properties of and hazards presented by chlorine can expose employees to corrosive, toxic, and oxidizing hazards.  c) Bleach Plant Pad, KIK Consumer Products, on or about June 26, 2023 - The employer did not develop written operating procedures that provide properties of and hazards presented by chlorine in the written operating procedure NP-026 Normal Operating Procedure Powell ProVent Process Scrub. Failure to develop operating procedures that provide properties of and hazards presented by chlorine can expose employees to corrosive, toxic, and oxidizing hazards.  d) Railcar Unloading Station, KIK Consumer Products, on or about June 26, 2023 - The employer did not develop written operating procedures that provide properties of and hazards presented by chlorine in the written operating procedure NP-001 Normal Operating Procedure Chlorine Railcar Disconnection. Failure to develop operating procedures that provide properties of and hazards presented by chlorine can expose employees to corrosive, toxic, and oxidizing hazards.

Issued

Dec 5, 2023

Abate by

Dec 22, 2023

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR  1910.119(f)(1)(iii)(C): The employer did not develop and implement written operating procedures that provide control measures to be taken if physical contact or airborne exposure occurs:   a) Railcar Unloading Station, KIK Consumer Products, on or about June 26, 2023 - The employer did not develop written operating procedures that provide control measures to be taken if physical contact or airborne exposure to chlorine occurs in the written operating procedure NP-003 Normal Operating Procedure Chlorine Railcar Connection. Failure to develop operating procedures that provide control measures to be taken if physical contact or airborne exposure to chlorine occurs can expose employees to corrosive, toxic, and oxidizing hazards.  b) Bleach Plant Pad, KIK Consumer Products, on or about June 26, 2023 - The employer did not develop written operating procedures that provide control measures to be taken if physical contact or airborne exposure to chlorine occurs in the written operating procedure NP-004 Normal Operating Procedure Powell Continuous Bleach Plant Automatic Startup. Failure to develop operating procedures that provide control measures to be taken if physical contact or airborne exposure to chlorine occurs can expose employees to corrosive, toxic, and oxidizing hazards.  c) Bleach Plant Pad, KIK Consumer Products, on or about June 26, 2023 - The employer did not develop written operating procedures that provide control measures to be taken if physical contact or airborne exposure to chlorine occurs in the written operating procedure NP-026 Normal Operating Procedure Powell ProVent Process Scrub. Failure to develop operating procedures that provide control measures to be taken if physical contact or airborne exposure to chlorine occurs can expose employees to corrosive, toxic, and oxidizing hazards.  d) Railcar Unloading Station, KIK Consumer Products, on or about June 26, 2023 - The employer did not develop written operating procedures that provide control measures to be taken if physical contact or airborne exposure to chlorine occurs in the written operating procedure NP-001 Normal Operating Procedure Chlorine Railcar Disconnection. Failure to develop operating procedures that provide control measures to be taken if physical contact or airborne exposure to chlorine occurs can expose employees to corrosive, toxic, and oxidizing hazards.

Issued

Dec 5, 2023

Abate by

Jan 9, 2024

Penalty

Initial $10,046 · Current $6,000 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR  1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and did not document that deficiencies had been corrected:  a) In the Facility, on or about June 26, 2023 - The employer did not document that deficiencies (items listed below) identified in their 2021 compliance audit had been corrected, exposing employees to corrosive, toxic, and oxidizing hazards.    (a) Item 1: Section C, Question #21, 22, 23, 24, SOP training records not available for all processing employees. Initial training and recertification training is required at 3 year intervals.  (b) Item 2: Section C, Question #25, 26, Records of SOP training and operational training do not include the method used to verify understanding.  (c) Item 3: Section C, Question #29, Pressure test on the unloading valves that should be conducted weekly was last performed on 4/12/2021.  (d) Item 4: Section C, Question #29, Field ID completion rate at 86% for 2020 and 95% for 2021 Target completion rate is 98%.  (e) Item 5: Section C, Question #29, Safety Chlorine Block Valves were not changed out and rebuilt at annual interval.  (f) Item 6: Section C, Question #29, ORP Probes found not to have been inspected, cleaned, or replaced at required interval.  (g) Item 7: Section C, Question #41, A few MOC's missing signatures verifying completion of the updating of the SOP that is covered by the change.  (h) Item 8: Section C, Question #42, One PSSR was missing confirmation that the post event items were completed.  (i) Item 9: Section F, Question 1, Contractor prequalification documentation and training not found for one contractor was not located. (Giancarlo for calibration of CL2 detection).  (j) Item 10: Section F, Question 5, Post project evaluation forms have yet to be implemented to review the contractors performance during or after the work has been completed.  (k) Item 11: Section G, Question 11, New RMP regulations will required the side to perform annual notification drills to verify that emergency contact information is available and correct. (Effective 2024).  (l) Item 12: Section G, Question 12, Chlorine tabletop shall be performed with local first responders at intervals not to exceed 3 years (Effective 11/2026).  (m) Item 13: Section G, Question 13, Facility has not documented Chlorine Emergency Response Field Exercise with local responders (Effective date is 11/2023).