OSHA Inspection: ROEHM AMERICA, LLC

Issued

Sep 4, 2025

Abate by

Oct 22, 2025

Penalty

Initial $16,550 · Current $16,550

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that the equipment complies with recognized and generally accepted good engineering practices.  a) On or around March 7, 2025, in the -26 degrees Celsius Ammonia Refrigeration Chiller area, the employer did not comply with the employer's selected Recognized And Generally Accepted Good Engineering Practice (RAGAGEP) ANSI/HAR 2-2021, when the employees and contractors were performing commissioning and startup activities and the termination of pressure relief vent headers was not directed upward to relieve anhydrous ammonia to the atmosphere.  b) On or around March 6, 2025, in the -26 degrees Celsius Ammonia Refrigeration Chiller area, the employer did not comply with the employer's selected Recognized And Generally Accepted Good Engineering Practice (RAGAGEP) ANSI/HAR 2-2021, when the employees and contractors were performing commissioning and startup activities and the termination of pressure relief vent headers was not directed upward to relieve anhydrous ammonia to the atmosphere.

Issued

Sep 4, 2025

Abate by

Oct 22, 2025

Penalty

Initial $16,550 · Current $16,550

General-duty citation text

29 CFR 1910.119(e)(1): The process hazard analysis was not appropriate to the complexity of the process:  On or around March 7, 2025, in the -26 degrees Celsius Ammonia Refrigeration Chiller area, the employer failed to identify, evaluate, and manage the hazardous conditions associated with Ammonia Refrigeration Chiller skid, while the employees and contractors were performing commissioning and startup activities.

Issued

Sep 4, 2025

Abate by

Oct 22, 2025

Penalty

Initial $16,550 · Current $16,550

General-duty citation text

29 CFR 1910.119(i)(1): The employer did not perform a pre-startup safety review for new facilities when the modification was significant enough to require a change in the process safety information.  a) On or about March 7, 2025, and at times prior thereto, the employer did not perform a pre-startup safety review of Piping, valves, instrumentation and control systems that transfer flammable and toxic chemicals from Oxea Chemicals to their process units.   b) On or about March 7, 2025, and at times prior thereto, the employer did not perform a pre-startup safety review of Piping, valves, instrumentation and control systems of -26 Celsius Ammonia Refrigeration Chiller skid.

Issued

Sep 4, 2025

Abate by

Oct 22, 2025

Penalty

Initial $16,550 · Current $16,550

General-duty citation text

29 CFR 1910.119(i)(2)(ii): The pre-startup safety review did not confirm that prior to the introduction of highly hazardous chemicals to a process the safety, operating, maintenance, and emergency procedures were in place and were adequate:   a) On or around March 7, 2025, the employer failed to ensure that adequate safety, operating, maintenance, and emergency procedures were in place before starting up process units and equipment.  b) On or around March 6, 2025, the employer failed to ensure that adequate safety, operating, maintenance, and emergency procedures were in place before starting up process units and equipment.

Issued

Sep 4, 2025

Abate by

Oct 22, 2025

Penalty

Initial $16,550 · Current $16,550

General-duty citation text

29 CFR 1910.120(q)(1): The employer did not develop and implement an emergency response plan to handle anticipated emergencies prior to commencement of emergency response operations:  a) On or around March 7 2025, and at times prior thereto, the employer did not develop and implement an Emergency Response Plan, where there were releases of highly hazardous chemicals such as ammonia and DOE LIMA catalyst.   b) On or around March 7 2025, and at times prior thereto, an employee alarm system complying with the requirements of 1910.165 was not implemented where there were releases of highly hazardous chemicals such as ammonia and DOE LIMA catalyst.

Issued

Sep 4, 2025

Abate by

Oct 22, 2025

Penalty

Initial $16,550 · Current $16,550

Hazardous substances 01701290

General-duty citation text

29 CFR  1910.134(f)(6): Qualitative QLFT fit tests were performed on negative pressure air-purifying respirators when the required fit factor was greater than 100:     a) On or about March 7 2025, and at times prior thereto, the employer provided qualitative fit tests to employees using full face respirators such as the MSA Elite that required a fit factor of 500.

Issued

Sep 4, 2025

Abate by

Oct 22, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 1290

General-duty citation text

29 CFR  1910.134(k): The employer did not provide comprehensive, understandable training which did not occur annually and/or more often if necessary:   a) On or about March 7 2025, and at times prior thereto, employees required to use respirators during tasks such as, but not limited to,  opening process lines had not received effective training.

Issued

Sep 4, 2025

Abate by

Oct 22, 2025

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.134(k)(1)(iii): The employer did not ensure that each user could demonstrate knowledge of how to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions:    a) On or about March 7 2025, and at times prior thereto, employees required to use respirators during emergency situations such as, but not limited to, ammonia releases, did not know how to use their respirator effectively.

Issued

Sep 4, 2025

Abate by

Oct 22, 2025

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.134(k)(5): Respiratory protection retraining was not conducted annually:   a) On or about March 7 2025, and at times prior thereto, the employer did not ensure respirator protection retraining was conducted annually for all employee that use respirators.

Issued

Sep 4, 2025

Abate by

Oct 22, 2025

Penalty

Initial $16,550 · Current $16,550

Hazardous substances 0170

General-duty citation text

29 CFR  1910.1200(e)(1)(i): The employer did not compile a list of the hazardous chemicals known to be present using a product identifier that was referenced on the appropriate safety data sheet:   a) On or about March 7 2025, and at times prior thereto, the employer did not include anhydrous ammonia or DOE LIMA catalyst as part of the known hazardous chemical list present at the workplace.

Issued

Sep 4, 2025

Abate by

Oct 22, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR  1910.1200(h)(2)(ii): The employer did not provide information to the employees on operations in their work area where hazardous chemicals were present:   a) On or about March 7 2025, and at times prior thereto, employee training did not include the physical and health hazards of chemicals such as, but not limited to anhydrous ammonia or experimental DOE LIMA catalyst present at the workplace.