OSHA Inspection: BAE SYSTEMS ORDNANCE SYSTEMS INC.

Issued

Apr 23, 2024

Abate by

Apr 23, 2026

Penalty

Initial $9,795 · Current $9,795

Hazardous substances 017012101890

General-duty citation text

29 CFR 1910.119(f)(1)(ii): The employer's written operating procedures did not address the requirements for the operating limits:  a) Green Lines, Mix House, Bay 9: On or about February 14, 2024, the employer failed to address the operating limits in the written operating procedure, 4-02-009B - Preparation of Solvent Mixes, when employees prepared solvent mixtures using the flammable liquid, diethyl ether, in the makeup tank.  The vapors from the flammable liquid used in the solvent mixtures can ignite and expose employees to flash fire hazards.      b) Solvents Area: On or about February 14, 2024, the employer failed to address the operating limits in the written operating procedure, RAD-SV-418 - Transferring Ether Product from T7 to M10, when employees worked with diethyl ether.  Exposure to diethyl ether could lead to serious injury or death from chemical inhalation and fire hazards.  ABATEMENT CERTIFICATION REQUIRED  ABATEMENT NOTE:  The operating limits shall address the consequences of deviation and steps required to correct or avoid deviation.

Issued

Apr 23, 2024

Abate by

Apr 23, 2026

Penalty

Initial $9,795 · Current $9,795

Hazardous substances 01701210186018902310

General-duty citation text

29 CFR 1910.119(g)(3) Training documentation. 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:  a) On or about February 13, 2024, the employer failed to document that employees who work as operators adequately understood their training with respect to cross-references within the binders containing operating and other procedures as it relates to control measures to be taken if physical contact or airborne exposure occurs.  ABATEMENT CERTIFICATION REQUIRED

Issued

Apr 23, 2024

Abate by

Apr 23, 2026

Penalty

Initial $9,795 · Current $5,875 Reduced

Hazardous substances 09261210

General-duty citation text

29 CFR 1910.119(f)(1)(iv): The employer's written operating procedures did not address the requirements for the safety systems and their functions:  a) Green Lines, Mix House, Bay 9: On or about February 14, 2024, the employer failed to address the safety systems and their functions in the written operating procedure, 4-02-009B - Preparation of Solvent Mixes, when employees prepared solvent mixtures using the flammable liquid, diethyl ether, in the makeup tank.  The vapors from the flammable liquid used in the solvent mixtures can ignite and expose employees to flash fire hazards.      ABATEMENT CERTIFICATION REQUIRED

Issued

Apr 23, 2024

Abate by

Apr 23, 2026

Penalty

Initial $9,795 · Current $9,795

Hazardous substances 2310

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 (RAGAGEP):  a) The Employer failed to document appropriate inspection protocols as recommended by the original equipment manufacturer for Teflon-lined piping.  ABATEMENT CERTIFICATION REQUIRED

Issued

Apr 23, 2024

Abate by

Apr 23, 2026

Penalty

Initial $57,620 · Current $9,795 Reduced

Hazardous substances 017012102310

General-duty citation text

29 CFR  1910.119(j)(2): The employer did not establish or implement written procedures to maintain the on-going integrity of process equipment:  a) Legacy NC, C-Line NOx Abatement Facility: On or about October 24, 2023, the employer failed to establish written procedures for maintaining the integrity of controls, including the procedural steps to be followed for the inspection, testing, and calibration of the ammonia gas injection flow loop.  Failure of this control could result in a release of anhydrous ammonia and expose employees to serious injury or death from chemical inhalation and fire hazards.    b) Legacy NC, C-Line NC NOx Abatement Facility: On or about October 24, 2023, the employer failed to establish written procedures for maintaining the integrity of controls, including the procedural steps to be followed in the SCR acid control area for the inspection of the acid concentration diverter valve, scrubber tower dump valve, condensate tank level transmitter, scrubber tower level control valve, fume fan condensate catch box air operate pump or the mass flow meter.  Failure of these controls could result in a release of anhydrous ammonia and expose employees to serious injury or death from chemical inhalation and fire hazards.      c) Legacy NC, C-Line NOx Abatement Facility: On or about October 24, 2023, the employer failed to establish written procedures for maintaining the integrity of process equipment, including the procedural steps to be followed for the cleaning, calibrating, and catalyst replacement on the NOx analyzers.  Failure of this process equipment could result in a release of anhydrous ammonia and expose employees to serious injury or death from chemical inhalation and fire hazards.      d) Legacy NC, C-Line NOx Abatement Facility: On or about October 24, 2023, the employer failed to establish written procedures for maintaining the integrity of process equipment, including the procedural steps to be followed for the inspection and calibration of the fired heater.  Failure of this process equipment could result in a release of natural gas and expose employees to serious injury or death from fire and explosion hazards.  e) Legacy NC, Oleum Tank A, Attached Piping: On or about October 24, 2023, the employer failed to establish written procedures for maintaining the integrity of piping systems, including the steps to be followed for the inspection and testing of the oleum piping system.  Failure of this piping system could result in a release of oleum and expose employees to serious injury or death from chemical inhalation.      f) Legacy NC, Sulfuric Acid Tank B, Attached Piping: On or about October 24, 2023, the employer failed to establish written procedures for maintaining the integrity of piping systems, including the steps to be followed for the inspection and testing of the sulfuric acid piping system.  Failure of this piping system could result in a release of sulfuric acid and expose employees to serious injury or death from chemical inhalation.     ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED  The employer, BAE Systems Ordnance Systems, Inc., was previously cited for a violation of this Occupational Safety and Health Standard, which was contained in OSHA inspection number 1564950, citation number 01, item number 03a, and was affirmed as a final order on June 14, 2022, with respect to a workplace located at 4050 Pepper Ferry Road, Radford, VA 24141.  ABATEMENT NOTE: Written procedures to maintain the on-going integrity of process equipment shall detail how to perform inspections and tests that comply with the employer-selected recognized and generally accepted good engineering practices (RAGAGEP).

Issued

Apr 23, 2024

Abate by

Apr 23, 2026

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not implement procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process:  a) Legacy NC, NC Nitration Building: On or about October 25, 2023, the employer failed to implement management of change (MOC) procedures for the conversion from anhydrous ammonia to Freon for the brine chilling system which is part of an explosives process.    ABATEMENT CERTIFICATION REQUIRED

Issued

Apr 23, 2024

Abate by

Apr 23, 2026

Penalty

Initial $0 · Current $0

Hazardous substances 12102310

General-duty citation text

29 CFR  1910.1200(f)(6)(ii): Except as provided in 29 CFR 1910.1200(f)(7) and 29 CFR 1910.1200(f)(8), the employer did not ensure that each container of hazardous chemicals in the workplace was 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 and which, in conjunction with the other information immediately available to employees under the hazard communication program, would provide employees with the specific information regarding the physical and health hazards of the hazardous chemical:  a) Acid Area: On or about October 24, 2023, the employer failed to ensure that the sulfuric acid storage tanks T80, T81, T102, T103, T104, and T105 were appropriately labeled with words, pictures, symbols, or combination thereof that provided at least general information regarding the hazards of the chemicals within them.  b) Solvents Area: On or about October 25, 2023, the employer failed to ensure that the ether storage tanks T6, S9, and S10 were appropriately labeled with words, pictures, symbols, or combination thereof that provided at least general information regarding the hazards of the chemicals within them.  ABATEMENT CERTIFICATION REQUIRED  ABATEMENT NOTE:  Storage tanks are not stationary process containers and are not permitted to utilize the alternative labeling methods (e.g., placards) contained in paragraph (f)(7).