OSHA Inspection: DAP GLOBAL INC.

Issued

Aug 13, 2024

Abate by

Oct 31, 2024

Penalty

Initial $16,131 · Current $16,131

Hazardous substances 00402150K105

General-duty citation text

29 CFR 1910.119(e)(3)(vii): Process hazard analysis. The process hazard analysis shall 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 February 26, 2024, the employer's previous PHA did not adequately address recommendations such as but not limited to:   (a)  The failure of the glycol system heat exchanger and pump had no current safeguards.  It was stated that there needed to be a better understanding of the glycol system temperature and pressure to prevent the inconsistent propellant fill weights into cans, but the status was listed as "No actions required. Not credible."  (b)   The human factors section for relocating the controls located on the back side of AL1 Gas House, as there was little space for a person to reach the control.    (c)  The recommendations for upgrading sensors to detect poor crimps or missing valves in cans to prevent fire or explosion in the gas houses.  (e)  The recommendations for installing equipment to divert rejected cans from the gas houses to prevent spills, leaks and fires.

Issued

Aug 13, 2024

Abate by

Oct 31, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 00402150K105

General-duty citation text

29 CFR  1910.119(e)(5): Process hazard analysis. The employer shall establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; 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.  On or about February 26, 2024, the employer had not established a system to promptly address their previous process hazard analysis (PHA) findings and recommendations for the AL1 and AL2 Gas Houses, such as but not limited to:  (a)  developing and implementing mechanical integrity operating and inspection procedures for the Gas Houses;  (b)  establishing replacement schedules for seals and hoses used in the Gas House equipment;  (c)  replacing gauges on Gas House equipment that were covered in paint and unreadable;  (d)  upgrading sensors in the Gas Houses to better detect poor crimps or missing valves on spray cans;  (e)  develop and implement a written housekeeping program for process areas, especially the Gas Houses where cans can explode and spray paint all over, covering sensors, control switches and labels.

Issued

Aug 13, 2024

Abate by

Sep 30, 2024

Penalty

Initial $16,131 · Current $16,131

Hazardous substances 00402150K105

General-duty citation text

29 CFR 1910.119(j)(2):  Mechanical integrity - Written procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment.  (a)  On or about February 26, 2024, the employer had not established and utilized standard operating procedures (SOPs) that included the mechanical integrity of process equipment, such as but not limited to pressure vessels, storage tanks, piping systems, relief systems and devices, vent systems, emergency shutdown systems, controls and pumps for the AL1 and AL2 gas house processes.  (b) On or about February 26, 2024, the employer did not implement a procedure to clean the star wheel to keep paint cans from sticking to old paint from spills on the wheel which could cause more spills.

Issued

Aug 13, 2024

Abate by

Sep 30, 2024

Penalty

Initial $16,131 · Current $0 Reduced

Hazardous substances 00402150K105

General-duty citation text

29 CFR 1910.119(j)(3):  Mechanical integrity -Training for process maintenance activities. The employer shall train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner.  (a)  On or about February 26, 2024, the employer had not provided consistent training for all maintenance employees on the procedures necessary to maintain the mechanical integrity of the process equipment, such as but not limited to pressure vessels, storage tanks, piping systems, relief systems and devices, vent systems, emergency shutdown systems, controls and pumps for the AL1 and AL2 gas house processes.

Issued

Aug 13, 2024

Abate by

Oct 31, 2024

Penalty

Initial $16,131 · Current $0 Reduced

Hazardous substances 00402150K105

General-duty citation text

29 CFR 1910.119(j)(4):  Mechanical integrity. Inspection and testing:   1910.119(j)(4)(i):  Inspections and tests shall be performed on process equipment. 1910.119(j)(4)(ii): Inspection and testing procedures shall follow recognized and generally accepted good engineering practices. 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience. 1910.119(j)(4)(iv): The employer shall document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.  (a)   On or about February 26, 2024, the employer had not documented recognized and generally accepted good engineering practices (RAGAGEP) for covered equipment where needed.  (b)   On or about February 26, 2024, the employer did not know the frequency or schedule for inspections and tests performed on process equipment by an outside contractor.   (c)   On or about February 26, 2024, the employer did not have any documentation of inspections and tests performed on process equipment by an outside contractor.

Issued

Aug 13, 2024

Abate by

Oct 31, 2024

Penalty

Initial $16,131 · Current $1,294 Reduced

Hazardous substances 00402150K105

General-duty citation text

29 CFR 1910.132(d)(1)(i): Hazard assessment and equipment selection. The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall: Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment.   (a)  On or about February 26, 2024, the employer did not require flame resistant (FR) clothing for employees who worked in the gas houses, where they were exposed to high temperature, fire, and explosion hazards.