OSHA Inspection: LORD CORPORATION

Issued

2025-08-08 00:00:00

Abate by

2025-10-03 00:00:00

Penalty

Initial $16550.00 · Current $14700.00 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(C): The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting temporary operations:  a.) LORD Corporation, Building 8, on or about 02/09/25 and times prior thereto: the employer did not develop and implement written operating procedures that provided clear instructions for safely conducting Temporary operations when necessary during the production of Chemlock 6411.  Normal operations for Chemlock 6411 production involved an average production time of approximately 24 hours. During the production of batch initiated on 2/5/25, production operations were Idle for over 99 hours. Temporary operating procedures were not developed to ensure the process safety of the Mix Tank 2 during the extended production time. This hazardous condition exposed employees to severe injury due to the fire and explosion hazards posed by flammable liquids.

Issued

2025-08-08 00:00:00

Abate by

2025-10-03 00:00:00

Penalty

Initial $0.00 · Current $0.00

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.) LORD Corporation, Building 8, on or about 02/09/25 and times prior thereto: the employer made changes to Chemlok 6411 operating procedures during production from 2/5/25 to 2/9/25 without implementing management of change (MOC) procedures.  The changes included, but were not limited to, extended Idle operations of Mix Tank 2 and Mix Tank 5, monitoring and changing agitator speeds, checking ventilation connections, and performing audible and visual checks to ensure mixtures remained in solution.  MOC procedures were not initiated to ensure production operations remained within normal process safety limits.  This hazardous condition exposed employees to severe injury due to the fire and explosion hazards posed by flammable liquids.

Issued

2025-08-08 00:00:00

Abate by

2025-10-03 00:00:00

Penalty

Initial $16550.00 · Current $10000.00 Reduced

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.)LORD Corporation, Building 8, on or about 02/09/25 and times prior thereto: the employer's normal operating procedures for Chemlok 6411 production did not include steps to correct or avoid deviation from normal operations during Idle operations in that clear instructions for allowable durations of safe Idle operations were not developed.  This hazardous condition exposed employees to severe injury due to the fire and explosion hazards posed by flammable liquids.  b.)LORD Corporation, Building 8, on or about 02/09/25 and times prior thereto: the employer's operating procedures for Chemlok 6411 production did not include steps to correct or avoid deviation from normal operations during Mix Tank Idle operations. The normal operating procedure for Building 8-Chemlok Area did not include clear instructions and measurable parameters for visual observations of items during an Idle operation period including but not limited to agitator condition, agitator speeds, ventilation connections, product quantity levels in the mix tanks, hatch opening, Nitrogen flow,  and product mixture temperatures.  This hazardous condition exposed employees to severe injury due to the fire and explosion hazards posed by flammable liquids.

Issued

2025-08-08 00:00:00

Abate by

2025-10-03 00:00:00

Penalty

Initial $16550.00 · Current $10000.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process:  a.) LORD Corporation, Building 8, on or about 02/09/25 and times prior thereto: the employer's process hazard analysis (PHA) for Chemlok 6411 production operations did not address the hazards of Idle operations and prolonged Idle operations in Mix tanks.  Idle operations were not evaluated to determine the hazards associated with constant agitation and ventilation of the mixtures in the tanks.  This hazardous condition exposed employees to severe injury due to the fire and explosion hazards posed by flammable liquids.  b.) LORD Corporation, Building 8, on or about 02/09/25 and times prior thereto: the employer's Chemlok 6411 production operation PHA did not address the hazards associated with intermediary equipment failures during a batch production process involving multiple interconnected pieces of equipment.  This hazardous condition exposed employees to severe injury due to the fire and explosion hazards posed by flammable liquids.

Issued

2025-08-08 00:00:00

Abate by

2025-10-03 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(e)(3)(iii): The Process Hazard Analysis 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.) LORD Corporation, Building 8, on or about 02/09/25 and times prior thereto: the employer's Process Hazard Analysis (PHA) for Chemlok 6411 production operations did not identify applicable engineering and administrative controls for Idle operations that established a system of periodic checks for the duration of Idle operations to ensure the mixtures in the Mix Tanks remained within acceptable limits. This hazardous condition exposed employees to severe injury due to the fire and explosion hazards posed by flammable liquids.  b.)LORD Corporation, Building 8, on or about 02/09/25 and times prior thereto: the employer's PHA for Chemlok 6411 production operations did not identify applicable engineering and administrative controls for Idle operations to ensure the temperatures of the mixtures in Mix Tanks remained within acceptable limits for the duration of Idle operations. This hazardous condition exposed employees to severe injury due to the fire and explosion hazards posed by flammable liquids.  c.) LORD Corporation, Building 8, on or about 02/09/25 and times prior thereto: the employer's PHA for Chemlok 6411 production operations did not identify applicable engineering and administrative controls for Idle operations involving the routine lifting of the hatchway door to visually observe the mixtures in the Mix Tanks for the duration of Idle operations. This hazardous condition exposed employees to severe injury due to the fire and explosion hazards posed by flammable liquids.  d.) LORD Corporation, Building 8, on or about 02/09/25 and times prior thereto: the employer's PHA for Chemlok 6411 production operations did not identify applicable engineering and administrative controls for Idle operations for ensuring that the piped Nitrogen was flowing properly into Mix Tanks for the duration of Idle operations. This hazardous condition exposed employees to severe injury due to the fire and explosion hazards posed by flammable liquids.  e.) LORD Corporation, Building 8, on or about 02/09/25 and times prior thereto: the employer's PHA for Chemlok 6411 production operations did not identify applicable engineering and administrative controls for Idle operations for ensuring the quantity of the mixtures in the Mix Tanks remained consistent for the duration of Idle operations. This hazardous condition exposed employees to severe injury due to the fire and explosion hazards posed by flammable liquids.