OSHA Inspection: SPRAY PRODUCTS CORPORATION

Issued

Jul 22, 2024

Penalty

Initial $10,372 · Current $10,372

General-duty citation text

29 CFR  1910.37(a)(3):Exit route(s) were not kept free and unobstructed:  a) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462  - Gas house and Tank Farm Areas: On or about January 22, 2024, the employer failed to keep exits routes from the gas house free and unobstructed. In the event of an emergency, employees would have to travel over or under the gas house conveyor to access a safe location.    b) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462  - Gas house and Tank Farm Areas: On or about June 28, 2024, the employer failed to keep exit routes from the gas house free and unobstructed. A pallet of material was placed at the base of the egress stars obstructing the exit route.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $10,372 · Current $10,372

General-duty citation text

29 CFR  1910.106(d)(5)(vi)(e): Piles were closer than 3 feet to the nearest beam, chord, girder, sprinkler deflector or other obstruction:  a) 1323 Conshohocken Rd. Plymouth Meeting - On or about June 28, 2024, the employer failed to maintain the piles of flammable drums, boxes and containers stacked in piles at least 3 feet away from overhead girders and sprinkler deflectors.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $14,518 · Current $14,518

General-duty citation text

29 CFR  1910.106(e)(6)(ii): Category 1 or 2 flammable liquids, or Category 3 flammable liquids with a flashpoint below 100 �F (37.8 �C),  were dispensed into containers without the nozzle and container being electrically interconnected:  a) 1323 Conshohocken Rd. Plymouth Meeting - On or about June 28, 2024, an employee was observed dispensing a flammable liquid, identified as Cherry Orchidia, from a 30-gallon plastic drum, horizontally via gravity into an open plastic bucket without the nozzle and container being electrically interconnected.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $14,518 · Current $14,518

General-duty citation text

29 CFR  1910.119(d)(2)(i)(A): The employer did not include a block flow diagram or simplified process flow diagram as part of process safety information concerning technology of the process.   a) 1323 Conshohocken Rd. Plymouth Meeting, PA - On or about January 22, 2024, the employer failed to compile complete and accurate process safety information pertaining to the technology of the process, a block flow diagram had not been fully developed by the employer. Failure to include the block flow diagram could result in fire and delayed emergency response.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.119(d)(2)(i)(C): Information concerning the technology of the process did not include a maximum intended inventory of highly hazardous chemicals:  a) 1323 Conshohocken Rd. Plymouth Meeting, PA- On or about January 22, 2024, the employer failed to compile complete and accurate process safety information pertaining to the technology of the process, the maximum intended inventory for each product had not been developed by the employer. Failure to identify the maximum intended inventory can result in an over accumulation of flammables resulting in a release, exposing employees to fire.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.119(d)(2)(i)(E): The employer failed to perform an evaluation of the consequences of deviations, including those effecting the safety and health of employees.  a) 1323 Conshohocken Rd. Plymouth Meeting, PA- On or about January 22, 2024, the employer failed to compile complete and accurate process safety information pertaining to the technology of the process, an evaluation of the consequences of deviations, including those affecting the safety and health of employees was not included. Failure to evaluate the consequences of deviation can result in equipment operating outside of acceptable limits exposing employees to loss of containment of flammable materials, exposing employees to fire.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $14,518 · Current $14,518

General-duty citation text

29 CFR  1910.119(d)(3)(ii):The employer did not document that equipment complies with recognized and generally accepted good engineering practices.  a) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Warehouse (Building 1): On or about January 22, 2024, the employer did not comply with generally accepted good engineering practices (RAGAGEP) such as NFPA 13 when the sprinkler coverage area did not meet the design requirements where moderate to substantial amounts of flammables were stored.  b) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Batching Area (Building 1): On or about January 22, 2024, the employer did not comply with generally accepted good engineering practices (RAGAGEP) such as NFPA 13 when the sprinkler coverage area did not meet the design requirements where moderate to substantial amounts of flammables were used or mixed.  c) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Building 2 (wet sprinkler covered area): On or about January 22, 2024, the employer did not comply with generally accepted good engineering practices (RAGAGEP) such as NFPA 13 when the sprinkler coverage area did not meet the design requirements where moderate to substantial amounts of flammables were stored, used, or mixed.  Failure to install a sprinkler system meeting the design requirements could result in an uncontrolled fire event resulting in serious injury and possible death.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $14,518 · Current $14,518

General-duty citation text

29 CFR  1910.119(e)(1): The employer did not perform an initial process hazard analysis on processes covered by 29 CFR 1910.119:  a) 1323 Conshohocken Rd., Plymouth Meeting, PA, 19462 - Tank Farm Areas: On or about January 22, 2024, and times prior to, the employer did not perform a process hazard analysis to identify, evaluate, and control the hazards related to potential release of 152A, A108, NP-85, and other blended flammable materials in piping.  b) 1323 Conshohocken Rd., Plymouth Meeting, PA, 19462 - Tank Farm 1: On or about January 22, 2024, and times prior to, the employer did not perform a process hazard analysis to identify, evaluate, and control the hazards related to potential release of Blended mixtures, IPA, Heptane, Acetone, and other blended flammable materials in piping.  c) 1323 Conshohocken Rd., Plymouth Meeting, PA, 19462 - Tank Farm 2: On or about January 22, 2024, and times prior to, the employer did not perform a process hazard analysis to identify, evaluate, and control the hazards related to potential release of Blended mixtures, Diethylether, Heptane, and other blended flammable materials in piping.  d) 1323 Conshohocken Rd., Plymouth Meeting, PA, 19462 - Tank Farm 3: On or about January 22, 2024, and times prior to, the employer did not perform a process hazard analysis to identify, evaluate, and control the hazards related to potential release of Hexane, Xylenes, Toluene, D-95, and other blended flammable materials in piping.  e) 1323 Conshohocken Rd., Plymouth Meeting, PA, 19462 - Compressor Room: On or about January 22, 2024, and times prior to, the employer did not perform a process hazard analysis to identify, evaluate, and control the hazards related to potential release of Dimethyl Ether, 134A, and other blended flammable materials in piping.  f) 1323 Conshohocken Rd., Plymouth Meeting, PA, 19462 - Batch Room A: On or about January 22, 2024, and times prior to, the employer did not perform a process hazard analysis to identify, evaluate, and control the hazards related to potential release of Blended mixtures and other blended flammable materials in piping.  g) 1323 Conshohocken Rd., Plymouth Meeting, PA, 19462 - Batch Room B: On or about January 22, 2024, and times prior to, the employer did not perform a process hazard analysis to identify, evaluate, and control the hazards related to potential release of Blended mixtures and other blended flammable materials in piping.  Failure to conduct an initial PHA to identify, evaluate and control the hazards of the process could lead to a catastrophic release of flammable liquids and expose maintenance and batcher employees to flash fire hazards.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.119(e)(3)(i):The process hazard analysis did not address the hazards of the process.  a) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Tank Farm 1: On or about January 22, 2024 the employer failed to ensure the PHA addressed the hazards of flame impingement and fire protection of vessels which are minimally spaced.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(iii): The process hazard analysis (PHA) did not address engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases:  a) 1323 Conshohocken Rd., Plymouth Meeting, PA, 19462 - On or about January 22, 2024, the employer failed to ensure that the PHA addressed engineering and administrative controls as a means of safeguards in areas where over 10,000 pounds of flammables are present. Failure to address engineering and administrative controls could lead to a catastrophic release of flammable liquids and expose maintenance and batcher employees to flash fire hazards.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $14,518 · Current $14,518

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to assure that the recommendations are resolved in a timely manner; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; and communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions:  1323 Conshohocken Rd. Plymouth Meeting, PA 19428- On or about January 22, 2024, and at times prior thereto, the employer's established system, with respect to the 2020 Process Hazard Analysis (PHA) revalidation, did not assure for the timely resolutions to recommendations and the completion of actions as soon as possible, nor develop a written schedule of when actions are to be completed for the following PHA items, exposing employees to fire hazards posed by flammable chemicals in the event of an uncontrolled release.  a) PHA No. 1.4 Operating Procedure:  RECOMMENDATION(S) - Operating procedures do not identify Normal Operating Ranges and consequences of deviation and methods to correct deviation. This is an ongoing hazardous condition that can result in the release of flammable chemicals causing serious injury to employees.    b) PHA No. 1.2 Mechanical Integrity: RECOMMENDATION(S) - Do inspections and tests have a guidance document for completing inspections and tests.  Above ground tank inspections documentation did not have all required information. This is an ongoing hazardous condition that can result in the release of flammable chemicals causing serious injury to employees.  c) PHA No. 1.3 Mechanical Integrity: RECOMMENDATION(S) - All critical equipment is not inspected to recognized. LPG tanks are overdue for inspection.  Piping may be required at this time as well. Team Inc. is scheduled to be onsite 3 March 2020 for work assessment and to present proposal for work standards. This is an ongoing hazardous condition that can result in the release of flammable chemicals causing serious injury to employees.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $0 · Current $0

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 document that deficiencies have been corrected:  1323 Conshohocken Rd. Plymouth Meeting, PA 19428- On or about January 22, 2024, the employer failed to promptly document the corrections for deficiencies identified in their 2020 compliance audit, exposing employees to flammable liquids and gases in the event of an uncontrolled release. Deficiencies include the following:  a) Operating procedures not addressing consequences of deviation from operating limits, the steps required to correct or avoid the deviation, and the acceptable pressures or levels.  b) Inspection reports on tanks have not adequately documented the required information.    c) The facility has not covered basic spill response training for affected employees.  d) The facility has improved the follow-up on audit findings, but there were a few not completed without new target dates.  Failure to correct deficiencies can lead to a catastrophic release of flammable liquids and expose maintenance and batcher employees to flash fire hazards.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $14,518 · Current $14,518

General-duty citation text

29 CFR  1910.119(g)(1)(i): Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks.  a) 1323 Conshohocken Rd. Plymouth Meeting, PA, 19428- On or about January 22, 2024, and times prior to, the employer failed to provide training to employees involved in Process Safety Management (PSM) covered operating processes. Failure to train employees on the established SOP's places them at a heighten risk for injuries associated with explosion(s)/fire(s).

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $14,518 · Current $14,518

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) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Tank Farm Areas: On or about January 22, 2024, the employer failed to establish and implement written procedures for conducting inspections and testing of the pressure vessels and storage tanks exposing employees to fire and explosion hazards.   b) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Tank Farm Areas: On or about January 22, 2024, the employer failed to establish and implement written procedures for conducting inspections and testing of the process piping systems, and associated piping components, used for the transfer of materials around the facility.   c) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Tank Farm Areas: On or about January 22, 2024 the employer failed to establish and implement written procedures for conducting inspections and testing on the relief valves installed in the various vessels in the tank farm.   d) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Gas House: On or about January 22, 2024, the employer failed to establish and implement written procedures for conducting inspections and testing on the deluge system.  e) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Gas House: On or about January 22, 2024, the employer failed to establish and implement written procedures for conducting inspections and testing on the halon system.  f) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Gas House and Warehouse: On or about January 22, 2024, the employer failed to establish and implement written procedures for conducting inspections and testing on the sprinkler system.   g) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Gas House: On or about January 22, 2024, the employer failed to establish and implement written procedures for conducting inspections and testing on the explosion system.   Failure to develop written procedures for conducting testing and inspections of equipment can lead to undetected system degradation and ultimately the release of flammable liquids or gases exposing the employee to fire and explosion hazards.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $14,518 · Current $14,518

General-duty citation text

29 CFR  1910.119(j)(4)(i):The employer did not perform inspection and tests on process equipment  a) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - On or about January 22, 2024, the employer did not perform inspection and tests on tanks A108, A152, NP85, (70), and DME tanks.   b) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Tank Farm Areas: On or about January 22, 2024, the employer did not perform inspection and tests on process piping used for the transfer of materials around the facility.  c) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Tank Farm Areas: On or about January 22, 2024, the employer did not perform inspection and tests relief valves which are installed in the various vessels in the tank farm.   Failure to conduct testing and inspections of equipment can lead to undetected system degradation and ultimately the release of flammable liquids or gases exposing the employee to fire and explosion hazards.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment to maintain its mechanical integrity, was not consistent with applicable manufacturer's recommendations and good engineering practices, or more frequently determined to be necessary by prior operating experience.    a) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Tank Farm: On or about January 22, 2024 the employer did not inspect or test process equipment at a frequency consistent with applicable manufacturer's recommendations and good engineering practices such as API 570 and 653 or STI, where tanks were not inspected at least every 10 years.  b) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Warehouse and production areas: On or about January 22, 2024 the employer did not inspect or test process equipment at a frequency consistent with applicable manufacturer's recommendations and good engineering practices such as NFPA 80, where doors were not drop tested annually (last test 8/12/2022).  c) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Warehouse and production areas: On or about January 22, 2024 the employer did not inspect or test process equipment at a frequency consistent with applicable manufacturer's recommendations and good engineering practices such as NFPA 72, where fire alarms were not tested annually (last test 11/22/2021).  Failure to conduct equipment testing and inspections consistent with RAGAGEP can lead to undetected system degradation and ultimately the release of flammable liquids or gases exposing the employee to fire and explosion hazards.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $10,372 · Current $10,372

General-duty citation text

29 CFR  1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information on paragraph (d) of this section) before use:  a) 1323 Conshohocken Rd. Plymouth Meeting, PA 19462 - Tank Farm: On or about June 28, 2024 the employer did not correct deficiencies noted in the 2/24/24 TAI report where multiple points in Tank A108's shell were measured below the documented t(min) thickness. Failure to correct deficiencies in equipment outside acceptable limits can result in catastrophic release of flammable materials.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $29,036 · Current $29,036

General-duty citation text

29 CFR 1910.106(e)(2)(iv)(d): Flammable liquids were not drawn from or transferred into vessels, containers, or portable tanks within a building only through a closed piping system, from safety cans, by means of a device drawing through the top, or from a container or portable tanks by gravity through an approved self-closing valve:  a) 1323 Conshohocken Rd. Plymouth Meeting - On or about June 28, 2024, an employee was observed dispensing a flammable liquid, identified as Cherry Orchidia, from a 30-gallon plastic drum, horizontally via gravity into an open plastic bucket without use of a self-closing valve.  Spray Products Corporation was previously cited for a violation of this Occupational Safety and Health Standards, 1910.106(e)(2)(iv)(d), which was contained in OSHA Inspection Number 1715040, Citation Number 1, Item Number 1, and was affirmed as a final order on March 18, 2024 with respect to a workplace located at 1000 Lake Road Medina, OH 44256.

Issued

Jul 22, 2024

Abate by

Sep 6, 2024

Penalty

Initial $29,036 · Current $29,036

General-duty citation text

29 CFR  1910.119(f)(1): The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process.    a)1323 Conshohocken Rd. - On or about January 22, 2024, and times prior to, the employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities such as but not limited to gas house and LPG drop-trailer operations. Failure to develop and implement operating procedures with clear instructions places employees at a heighten risk for injuries associated with explosion(s)/fire(s).  Spray Products Corporation was previously cited for a violation of this Occupational Safety and Health Standards, 1910.119(f)(1), which was contained in OSHA Inspection Number 1715040, Citation Number 1, Item Number 2, and was affirmed as a final order on March 18, 2024, with respect to a workplace located at 1000 Lake Road Medina, OH 44256.