OSHA Inspection: THE LUBRIZOL CORPORATION

Issued

Jul 18, 2025

Abate by

Sep 4, 2025

Penalty

Initial $7,093 · Current $7,094

General-duty citation text

29 CFR  1910.119(d)(3)(i)(B):The employer's piping and instrument diagrams (P&IDs) were not accurate.  On or about 1/29/2025,  at the Lubrizol facility, piping and instrument diagrams (P&IDs) did not accurately reflect the process safety management covered process, including but not limited to:  a)	P&IDs for reactors (R3, R5, R6, and R7) and knockout pots (stainless steel-SS, glass-G and South plant-SP) do not indicate pipe sizes, pipe materials, assigned P&ID numbers, material flows, and assigned number or name tag for instruments.  b)	P&ID for Reactor R6 (200-PID-006, Rev. G, date 5/28/2024).      i.	  HV-204 valve was identified incorrectly.       ii.  Pressure transmitter PT-300 was labeled incorrectly.  c)	P&ID for Reactor R3 (200-PID-005, Rev. B, date 5/28/2024). Pressure transmitter PT-300 was labeled incorrectly.

Issued

Jul 18, 2025

Abate by

Sep 4, 2025

Penalty

Initial $16,550 · Current $8,275 Reduced

General-duty citation text

29 CFR 1910.119(f)(3): The operating procedures were not reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer did not annually certify that operating procedures were current and accurate.   On or about 1/29/2025 at the Lubrizol facility, standard operating procedures (SOPs) including "Material Transfer to Reactor Work Instructions" were not annually certified to ensure that they are current and accurate.

Issued

Jul 18, 2025

Abate by

Sep 4, 2025

Penalty

Initial $7,093 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of  process equipment.   On or about 1/29/2025, for the PSM-covered process at the Lubrizol facility, written procedures were not established for :   a) Testing the Pressure Transmitter PT-300 on reactor R3 (200-PID-0005 Rev. B).  b) Testing the Pressure Transmitter PT-300 on reactor R6 (200-PID-0006 Rev. G).  c) Testing the Pressure Transmitter PT-200 on reactor R5 (200-PID-0012 Rev. D).  d) Testing the Temperature Indicator Controller TIC-100 on reactor R5 (200-PID-0012 Rev. D).  e) Testing the Temperature Control Valves TCV-300 and TCV-400 on reactor R5 (200-PID-0012 Rev. D).  f) Testing and inspecting piping.

Issued

Jul 18, 2025

Abate by

Sep 4, 2025

Penalty

Initial $16,550 · Current $8,275 Reduced

General-duty citation text

29 CFR  1910.119(j)(4)(i):The employer did not perform inspection and tests on process equipment   On or about 1/29/2025, at the Lubrizol facility process equipment was not tested:    a) Testing of Pressure Transmitter PT-300 on reactor R3 (200-PID-0005 Rev. B) was not performed.  b) Testing of Pressure Transmitter PT-300 on reactor R6 (200-PID-0006 Rev. G) was not performed.  c) Testing of Pressure Transmitter PT-200 on reactor R5 (200-PID-0012 Rev. D) was not performed.  d) Testing of the Temperature Indicator Controller TIC-100 on reactor R5 (200-PID-0012 Rev. D) was not performed.  e) Testing of Temperature Control Valves TCV-300 and TCV-400 on reactor R5 (200-PID-0012 Rev. D) was not performed.

Issued

Jul 18, 2025

Abate by

Sep 4, 2025

Penalty

Initial $7,093 · Current $7,093

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).     On or about 1/29/2025, at the Lubrizol facility, corrosion rates for listed piping segments were not established in accordance with recognized and generally accepted good engineering practices (RAGAGEP) such as America Petroleum Institute (API) Standard 570 - 2009 (Piping Inspection Code: In-service Inspection, Rating, Repair, and Alteration of Piping Systems), Section 7.1.3 "Existing Piping Systems" for:  a)	Isopropyl alcohol (IPL) outlet line, P-2"-115-SS, from TK-120 through pump P-120 to product header (600-PID-00XX Rev. B).  b)	Methanol (MAOL) outlet line, P-3"-143-316-SS, from TK-116 to the product header (100-PID-0016 Rev. A).  c)	Formaldehyde outlet line, P-2"-106-SS, from TK-101 through pump P-101 to the product header (100-PID-0001 Rev. B).

Issued

Jul 18, 2025

Abate by

Oct 17, 2025

Penalty

Initial $7,093 · Current $0 Reduced

General-duty citation text

29 CFR  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:    On or about 1/29/2025, at the Lubrizol facility, the frequency of inspections and tests of process equipment was not in accordance with recommended and accepted good engineering practice (RAGAGEP):  a) External inspections of reactor R5 were not conducted at a frequency consistent with recognized and generally accepted good engineering practice, including the employer's own covered equipment criticality ranking and inspection frequency guidance.   b) Thickness measurements of reactor R3 were not conducted at a frequency consistent with recognized and generally accepted good engineering practice, including the employer's own covered equipment criticality ranking and inspection frequency guidance.   c) Thickness measurements of reactor R5  were not conducted at a frequency consistent with recognized and generally accepted good engineering practice, including the employer's own covered equipment criticality ranking and inspection frequency guidance.   d) Thickness measurements of reactor R6  were not conducted at a frequency consistent with recognized and generally accepted good engineering practice, including the employer's own covered equipment criticality ranking and inspection frequency guidance.

Issued

Jul 18, 2025

Abate by

Sep 4, 2025

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.119(j)(4)(iv): The employer did not document each inspection and test that has been performed on process equipment. The documentation did not 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.  On or about 1/29/2025, at the Lubrizol facility, inspections  were not documented for the following process equipment:  a)	Rupture disc of the pressure relief valve (PRV) on reactor R3 b)	Rupture disc of the pressure relief valve (PRV) on reactor R5 c)	Rupture disc of the pressure relief valve (PRV) on reactor R6