OSHA Inspection: SEYMOUR OF SYCAMORE LLC

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $11916.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.110(b)(6)(viii): Suitable means shall be taken to prevent the accumulation of flammable liquids under adjacent liquefied petroleum gas containers, such as by diking, diversion curbs, or grading.   On or about May 7, 2025, and at times prior, the employer did not ensure the Propellant Tank Farm was provided with suitable means to prevent the accumulation of flammable liquids under adjacent liquefied petroleum gas containers, such as by diking, diversion curbs, or grading. The Propellant Tank Farm consists of 1- 30,000-gallon NP-80 (B-80 Propane/n-Butane mix) tank, 1- 12,000-gallon NP-80 (B-80 Propane/n-Butane mix) tank, and 1- 5,500-gallon Dimethyl Ether tank. Employees are exposed to potential fire and/or explosion which could result in severe burns, life altering disabilities, and death.  Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.110(b)(8) Piping - including pipe, tubing, and fittings. 29 CFR 1910.110(b)(8)(vi): The use of threaded cast iron pipe fittings such as ells, tees, crosses, couplings, and unions is prohibited. Aluminum alloy fittings shall be used with aluminum alloy pipe and tubing. Insulated fittings shall be used where aluminum alloy pipe or tubing connects with a dissimilar metal.  On or about May 7, 2025, and at times prior, the employer used threaded cast iron pipe fittings such as ells, tees, crosses, couplings, and/or unions throughout process piping, in the Propellant Tank Farm, and at a fill station installed outside of Line 4 charge room/doghouse. This fill station is attached to NP-80 (B-80 Propellant) Schedule 80 piping within the Line 4 doghouse through a hole in the exterior wall. Employees are exposed to potential fire and/or explosion which could result in severe burns, life altering disabilities, and death.  Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $8513.00 · Current $4665.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i) Information concerning the technology of the process shall include at least the following: 29 CFR 1910.119(d)(2)(i)(B): Process chemistry.  On or about March 13, 2025, and at times prior, the employer failed to document, compile, and maintain complete and accurate process chemistry information, required by the standard, pertaining to the covered process, Aerosol Spray Paint Can Filling process to include Class 1 Division 1 manufacturing areas (gas houses). The employer did not provide complete and accurate chemistry for the Propane-Butane Propellant storage tanks pertaining to the covered process. Employees were exposed to potential fire and/or explosion hazards which could result in severe burns, life altering disabilities, and death.  Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(d)(2)(i) Information concerning the technology of the process shall include at least the following: 29 CFR 1910.119(d)(2)(i)(C): Maximum intended inventory.  On or about March 13, 2025, and at times prior, the employer failed to document, compile, and maintain the maximum intended inventory, as required by the standard, pertaining to the covered process, Aerosol Spray Paint Can Filling process to include Class 1 Division 1 manufacturing areas (gas houses). Employees were exposed to potential fire and/or explosion hazards which could result in severe burns, life altering disabilities, and death.  Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(d)(2)(i) Information concerning the technology of the process shall include at least the following: 29 CFR 1910.119(d)(2)(i)(D): Safe upper and lower limits for such items as temperatures, pressures, flows or compositions.  On or about March 13, 2025, and at times prior, the employer failed to document, compile, and maintain safe upper and lower limits, as required by the standard, pertaining to the covered process, Aerosol Spray Paint Can Filling process to include Class 1 Division 1 manufacturing areas (gas houses). Such as but not limited to, an upper limit for pressure during the filling process.  Employees were exposed to potential fire and/or explosion hazards which could result in severe burns, life altering disabilities, and death.  (a) The employer failed to document, compile, and maintain the safe upper and lower limits for the 30,000-gallon propellant tank. (b) The employer failed to document, compile, and maintain the safe upper and lower limits for the 12,000-gallon propellant tank. (c) The employer failed to document, compile, and maintain the safe upper and lower limits for the 5,500-gallon propellant tank. (d) The employer failed to document, compile, and maintain the safe upper and lower limits for the process lines and equipment pertaining to the covered process.   Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(d)(2)(i) Information concerning the technology of the process shall include at least the following: 29 CFR 1910.119(d)(2)(i)(E): An evaluation of the consequences of deviations, including those affecting the safety and health of employees.  On or about March 13, 2025, and at times prior, the employer failed to evaluate, document, compile, and maintain an evaluation for the consequences of deviations, as required by the standard, pertaining to the covered process, Aerosol Spray Paint Can Filling process to include Class 1 Division 1 manufacturing areas (gas houses). Employees were exposed to potential fire and/or explosion hazards which could result in severe burns, life altering disabilities, and death.  Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $11916.00 · Current $6541.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i): Information pertaining to the equipment of the process did not include: 29 CFR 1910.119(d)(3)(i)(B): Complete and accurate piping and instrument diagram (P&ID's)   On or about March 13, 2025, and at times prior, the employer failed to evaluate, document, compile, and maintain complete and accurate written process safety information, required by the standard, pertaining to the covered process, Aerosol Spray Paint Can Filling process to include Class 1 Division 1 manufacturing areas (gas houses).    On or about March 20, 2025, copies of the Piping & Instrumentation Diagrams (P&ID's) for the entire system/process, alarms, and ventilation system were requested. The employer failed to provide completed piping and instrument diagram (P&ID's) and failed to ensure existing (P&ID's) were accurate. Employees were exposed to potential fire and/or explosion hazards which could result in severe burns, life altering disabilities, and death due to the following instances:   (a) The "PROPELLANT PIPING UNDER 30,000 GAL TANK" and "PROPELLANT PIPING(Under 12,000 gal. tank" P&ID's do not display pressure relief valve size, pressure relief angle, or the pressure setting for each pressure relief device.   (b) The employer failed to evaluate, document, compile, and maintain a P&ID for the 5,500 Dimethyl Ether tank, piping, and instrumentation.   (c) The employer failed to evaluate, document, compile, and maintain P&ID's displaying piping and instrumentation from the tanks to the pumps, above the tank, or the overhead runs to the individual Charging Operation Gas Houses (Dog Houses).   (d) The employer failed to evaluate, document, compile, and maintain P&ID's for the piping and instrumentation within the 3 Charging Operation Gas Houses (Dog Houses).   (e) The employer failed to evaluate, document, compile, and maintain P&ID's from the tank(s) to the Line 4 Propellant Booster Pump.   (f) The employer failed to evaluate, document, compile, and maintain P&ID's for the filling station installed outside of Line 4 Charging Operation Gas House (Doghouse), which is ran through a hole in the block wall and connected to the propellant line supplying the Charging Operations within the Gas House (Doghouse).   Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(d)(3)(i): Information pertaining to the equipment of the process did not include: 29 CFR 1910.119(d)(3)(i)(C): Electrical classification   On or about March 13, 2025, and at times prior, the employer failed to evaluate, document, compile, and maintain the electrical classification, required by the standard, pertaining to the covered process, Aerosol Spray Paint Can Filling process.  Employees were exposed to potential fire and/or explosion hazards which could result in severe burns, life altering disabilities, and death.  Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(d)(3)(i): Information pertaining to the equipment of the process did not include: 29 CFR 1910.119(d)(3)(i)(D): Relief system design and design basis.  On or about March 13, 2025, and at times prior, the employer failed to evaluate, document, compile, and maintain information on the location, design and design basis for all pressure relief devices and their respective terminal discharges pertaining to the covered process, Aerosol Spray Paint Can Filling. Employees were exposed to potential fire and/or explosion hazards which could result in severe burns, life altering disabilities, and death.   (a) On or about March 18, 2025, the employer failed to evaluate, document, compile, and maintain the relief system design and design basis for 1- 30,000-gallon propane mixed gas propellant pressure vessel (serial number 109991-01-3), located in the Propellant Tank Farm. (b) On or about March 18, 2025, the employer failed to evaluate, document, compile, and maintain the relief system design and design basis for 1- 12,000-gallon propane mixed gas propellant pressure vessel (serial number 48148), located in the Propellant Tank Farm.  (c) On or about March 18, 2025, the employer failed to evaluate, document, compile, and maintain the relief system design and design basis for 1- 5,500-gallon dimethyl ether propellant pressure vessel (serial number 116898), located in the Propellant Tank Farm.   (d) On or about March 18, 2025, the employer failed to evaluate, document, compile, and maintain the relief system design and design basis for the equipment within the manufacturing areas (gas houses), such as but not limited to the  Line 4 Booster Pump, which steps operating pressure up from ~130 psi to ~600 psi to the Line 4 Charge Head.   Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(d)(3)(i): Information pertaining to the equipment of the process did not include: 29 CFR 1910.119(d)(3)(i)(E): Ventilation system design.  On or about March 13, 2025, and at times prior, the employer failed to document, compile, and maintain written process safety information pertaining to the ventilation system design pertaining to the covered process, Aerosol Spray Paint Can Filling process to include Class 1 Division 1 manufacturing areas (gas houses). Employees were exposed to potential fire and/or explosion hazards which could result in severe burns, life altering disabilities, and death.   (a) On or about March 18, 2025, the employer failed to document the process safety information pertaining to the design and design basis of the ventilation system installed in the Line 1 Charge Room (Dog House), including but not limited to information pertaining to normal ventilation, emergency ventilation and shutdown controls, and rate of exhaust. (b) On or about March 18, 2025, the employer failed to document the process safety information pertaining to the design and design basis of the ventilation system installed in the Line 2 Charge Room (Dog House), including but not limited to information pertaining to normal ventilation, emergency ventilation and shutdown controls, and rate of exhaust. (c) On or about March 18, 2025, the employer failed to document the process safety information pertaining to the design and design basis of the ventilation system installed in the shared Charge Room (Dog House) for Lines 3 and 4, including but not limited to information pertaining to normal ventilation, emergency ventilation and shutdown controls, rate of exhaust, and the differences in ventilation requirements for Line 4 which operates at ~600 psi instead of ~130 psi.  Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $11916.00 · Current $6541.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(1): The employer shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. Employers shall determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process. The process hazard analysis shall be conducted as soon as possible, but not later than the schedule described in 1910.119(e)(1)(i)-(v).  On or about March 13, 2025, and at times prior, the employer failed to perform an initial process hazard analysis (hazard evaluation) pertaining to the covered process, Aerosol Spray Paint Can Filling process to include Class 1 Division 1 manufacturing areas (gas houses). The process utilizes a pressurized NP-80 Propane (62%)/n-Butane (38%) mixture referred to as B-80 and pressurized Dimethyl Ether (DME) in excess of 10,000 pounds. Employees are exposed to potential fire and/or explosion which could result in severe burns, life altering disabilities, and death.   Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $11916.00 · Current $6541.00 Reduced

General-duty citation text

29 CFR 1910.119(f)(1): The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the elements and steps for each operating phase described in 1910.119(f)(1)(A)-(G).  On or about March 13, 2025, and at times prior, the employer failed to document, maintain, and implement written operating procedures for the Aerosol Spray Paint Can Filling covered processes, exposing employees operating the Paint Fill lines to potential fire and explosion which could result in severe burn injuries, life altering disabilities, and death.   The following processes were documented to have no procedures or steps for 1910.119(f)(1)(i)(A) Initial Start-Up, 1910.119(f)(1)(i)(B) Normal Operations, 1910.119(f)(1)(i)(C) Temporary Operations, 1910.119(f)(1)(i)(D) Emergency Shutdown, 1910.119(f)(1)(i)(E) Emergency Operations, 1910.119(f)(1)(i)(F) Normal Shutdown, or 1910.119(f)(1)(i)(G) Startup following a turnaround or after an emergency shutdown:   (a) Line 1 Paint Fill Operations and Charge Room Operations (b) Line 2 Paint Fill Operations and Charge Room Operations (c) Line 3 Paint Fill Operations and Charge Room Operations (d) Line 4 Paint Fill Operations and Charge Room Operations (e) Remote Propellant Tank Fill Station Operations located outside of Line 4 Charge Room  Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(g)(1): Initial training. 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.  On or about March 13, 2025, and at times prior, the employer failed to document, maintain, and provide training to each employee presently involved in operating the covered process, Aerosol Spray Paint Can Filling process to include Class 1 Division 1 manufacturing areas (gas houses), as required by the standard. Employees are exposed to potential fire and/or explosion which could result in severe burns, life altering disabilities, and death. The following instanced were identified:  (a) Line 1 Paint Fill Operations and Charge Room Operations- The employer failed to provide and/or document training which includes an emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to each employee's job tasks. (b) Line 2 Paint Fill Operations and Charge Room Operations- The employer failed to provide and/or document training which includes an emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to each employee's job tasks. (c) Line 3 Paint Fill Operations and Charge Room Operations- The employer failed to provide and/or document training which includes an emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to each employee's job tasks. (d) Line 4 Paint Fill Operations and Charge Room Operations- The employer failed to provide and/or document training which includes an emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to each employee's job tasks. (e) Remote Propellant Tank Fill Station Operations located outside of Line 4 Charge Room- The employer failed to provide and/or document training which includes an emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to each employee's job tasks.  Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $11916.00 · Current $6541.00 Reduced

General-duty citation text

29 CFR 1910.119(f)(4): The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel.   On or about March 13, 2025, and at times prior, the employer failed to document, maintain, and implement safe work practices to provide for the control of hazards during operations, as required by the standard, pertaining to the covered process, Aerosol Spray Paint Can Filling process to include Class 1 Division 1 manufacturing areas (gas houses). Failure to develop and implement safe work practices exposes to potential fire and/or explosion which could result in severe burns, life altering disabilities, and death.  (a) On or about May 7, 2025, and at times prior, the employer failed to develop procedures or policies to prevent unauthorized entry of visitors, contractors, lab personnel and other support staff or the public from entering into the gas houses (dog houses) or process areas pertaining to the covered process.  (b) On or about May 7, 2025, and at times prior, the employer failed to develop procedures or policies to prevent unauthorized entry of visitors, contractors, lab personnel and other support staff or the public from entering into the Propellant Tank Farm pertaining to the covered process. Although the tank farm has a perimeter gate, the access doors are open and not secured.  (c) On or about July 1, 2025, and at times prior, the employer failed to implement the use of lockout tagout when performing servicing and maintenance of process equipment, charge heads, and charging equipment in the gas houses (dog houses) and the propellant tank farm.  (d) On or about July 14, 2025, and at times prior, the employer failed to develop safe work practice procedures prior to employees opening process equipment, such as conducting line breaks on Line 1 and Line 2 to connect and run the Dimethyl Ether propellant.  (e) On or about July 1, 2025, and at times prior, the employer failed to develop safe work practice procedures prior to employees conducting pre-run weight checks in the gas houses (dog houses), which includes expelling propellant from the can tested/weighed, inside the gas houses.   Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $11916.00 · Current $6541.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): Written procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment.  On or about March 13, 2025, and at times prior, the employer failed to document, maintain, and implement written procedures to maintain the on-going integrity of the equipment pertaining to the covered process, Aerosol Spray Paint Can Filling process to include Class 1 Division 1 manufacturing areas (gas houses). Failure to develop and implement procedures can result in the release of highly flammable gases under pressure, exposing employees to fire and explosion hazards.   (a) The employer failed to establish written procedures for piping inspection and testing to maintain the on-going integrity of the piping thickness minimums (tmin) for the ongoing integrity schedule 80 above ground pressure piping feeding into the gas houses (dog houses) in order to determine the remaining life and replacement of process piping circuits. (b) The employer failed to establish written procedures for piping inspection and testing to maintain the on-going integrity of the schedule 80 pressure piping feeding into the charging operations equipment within the gas houses (doghouses). (c)  The employer failed to establish written procedures for piping inspection and testing to maintain the on-going integrity of propellent injection equipment (charging heads) for inspection, replacement and frequency of the gaskets.  (d) The employer failed to establish written procedures for piping inspection and testing to maintain the on-going integrity of the schedule 80 pressure piping for Line 4 Charging Operations and Line 4 Propellant Booster Pump within the shared Line 3 & 4 gas house (doghouse). Line 4 operates at approximately 600 psi compared to the other lines operating at approximately 130 psi.  (e) The employer failed to establish written procedures for piping inspection and testing to maintain the on-going integrity of the piping ran from the Line 3 & 4 shared gas house through the wall to a satellite propellant filling station. (f) The employer failed to establish written procedures for piping inspection and testing to maintain the on-going integrity of pressure vessels, in the Propellant Tank Farm, used to feed the process with propellant gases.    Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $0.00 · Current $0.00

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.  The employer failed to document, maintain, and implement mechanical integrity training for maintenance activities to assure the safe operation and maintenance of process equipment, pertaining to the covered process, Aerosol Spray Paint Can Filling process to include Class 1 Division 1 manufacturing areas (gas houses), as required by the standard. Employees are exposed to potential fire and/or explosion which could result in severe burns, life altering disabilities, and death.   On or about March 13, 2025, and at times prior, the employer's maintenance employees did not receive training that included an overview of the covered process, process hazards and in procedures related to mechanical integrity tasks. The employer failed to perform training for maintenance employees who perform mechanical integrity activities to assure on-going safe operation of process equipment, such as the changing of DME supply line from B-80 supply line for the Line 1 and 2 charging process. Maintenance employees are exposed to potential fire and/or explosion which could result in severe burns, life altering disabilities, and death.  Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $11916.00 · Current $6541.00 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 March 13, 2025, and at times prior, the employer failed ensure inspection and testing frequencies were consistent with manufacturer's recommendations and good engineering practices, pertaining to the covered process, Aerosol Spray Paint Can Filling process to include Class 1 Division 1 manufacturing areas (gas houses). Employees were exposed to potential fire and/or explosion hazards which could result in severe burns, life altering disabilities, and death. The following instances were identified:   (a) The employer failed to inspect and test the 30,000-gallon Propellant Vessel on a schedule, or frequency that is consistent with good engineering practices. The equipment was inspected on June 25, 2018, with the completion of an in-service API 510 inspection by a certified inspector. The 2018 inspection required an external inspection within 5 years, stated that an internal inspection was past due and that performance of inspection/testing, or replacement of relief devices occurs within one year. An external inspection has not occurred since 2018; the vessel has never received a documented internal inspection and relief device inspection (or replacement) has not occurred.  (b) The employer failed to inspect and test the 12,000-gallon Propellant Vessel on a schedule, or frequency that is consistent with good engineering practices. The equipment was inspected on June 25, 2018, with the completion of an in-service API 510 inspection by a certified inspector. The 2018 inspection required an external inspection within 5 years and that performance of inspection/testing, or replacement of relief devices occurs within one year. An external inspection has not occurred since 2018; the vessel has never received a documented internal inspection and relief device inspection (or replacement) has not occurred.  (c) The employer failed to inspect and test the DME Vessel on a schedule, or frequency that is consistent with good engineering practices. The equipment was inspected on June 25, 2018, with the completion of an in-service API 510 inspection by a certified inspector. The 2018 inspection required an external inspection within 5 years, stated that an internal inspection was past due and that performance of inspection/testing, or replacement of relief devices occurs within one year. An external inspection has not occurred since 2018; the vessel has never received a documented internal inspection and relief device inspection (or replacement) has not occurred.  Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-04-30 00:00:00

Penalty

Initial $11916.00 · Current $6541.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(5): Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner, when necessary, means are taken to assure safe operation.  On or about March 13, 2025, and at times prior, the employer failed to correct deficiencies identified in equipment, pertaining to the covered process, Aerosol Spray Paint Can Filling process to include Class 1 Division 1 manufacturing areas (gas houses), in a safe and timely manner. Employees were exposed to potential leaks from pressure vessels, piping, and process equipment which could lead to fire and/or explosion resulting in severe burns, life altering disabilities, and death.  (a) The employer failed to correct all deficiencies identified in the 2018 30,000-gallon Propellant Vessel Inspection. Deficiencies were identified during an API 510 inspection and were not corrected that included the recommended replacement of existing relief devices, replacing illegible pressure gauges, repairing damage to concrete support saddles with exposed internal rebar, and installation of a replacement vessel data plate.  (b) The employer failed to correct all deficiencies identified in the 2018 12,000-gallon Propellant Vessel Inspection. Deficiencies were identified during an API 510 inspection and were not corrected that included the recommended replacement of existing relief devices, replacing illegible pressure gauges, installation of a replacement vessel data plate, and replacement of corroded exhaust piping on the outlet side of the relief valves. (c) The employer failed to correct all deficiencies identified in the 2018 5,500-gallon Dimethyl Ether Vessel Inspection. Deficiencies were identified during an API 510 inspection and were not corrected that included the recommended replacement of existing relief devices, removal and/or repair of fireproofing material covering the steel supports, replacing illegible pressure gauges, and replacement of corroded exhaust piping on the outlet side of the relief valves. (d) The employer failed to correct deficiencies related to corrosion of storage tanks and related piping. The corrosion identified on the March 18, 2025, weekly tank inspection form completed by the employer for the 30,000-gallon Propellant Vessel, 12,000-gallon Propellant Vessel, and 5,500-gallon Dimethyl Ether Vessel piping and exterior of the tanks was not repaired by treatment and recoating. (e) The employer failed to correct deficiencies for Line #1, Line #2, Line #3 & #4 Charge Room Mister Systems identified as malfunctioning due to corrosion or otherwise did not activate during Facility Inspections with the most recent performed on or about April 30, 2025, and dating back to January 24, 2024.  Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

2025-09-05 00:00:00

Abate by

2026-03-31 00:00:00

Penalty

Initial $11916.00 · Current $6548.00 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer shall establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and changes to facilities that affect a covered process.  On or about March 13, 2025, and at times prior, the employer  failed to document, maintain, and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and changes to facilities that affect a covered process, Aerosol Spray Paint Can Filling process to include Class 1 Division 1 manufacturing areas (gas houses), as required by the standard. Employees are exposed to potential fire and/or explosion which could result in severe burns, life altering disabilities, and death.  (a) The employer failed to implement a management of change procedure for the installation of an additional production line. The employer installed an additional aerosol spray paint can filling process in the North building, Line 6. The employer did not document a management of change procedure, failed to update process safety information, and failed to document safe operating procedures. (b) The employer failed to implement a management of change procedure for a change in chemical use in the covered process. The employer's process chemical information states the use of "A-80" propellant; however, the employer now uses a product referred to as "B-80," Diversified NP-80 (62% Propane and 38% n-Butane), and a product referred to as "AB-80," Aeropres AB80 (68.27% Propane and 31.73% Butane). The employer did not document a management of change procedure, failed to update process safety information, failed to update or develop safe operating procedures, and did not provide training or communication of the change to effected employees.  (c) The employer failed to implement a management of change procedure for process piping changes involved with DME use. The employer runs products on Line 1 and Line 2 which require Dimethyl Ether (DME) instead of "B-80" or "AB-80." This process chemical change results in the need to alter process piping. The employer conducts a line break to supply DME for the process change. There is no management of change procedure documented, an updated procedure has not been developed, process safety information is not updated, and an equipment, line purging, or evacuation process does not occur to address the physical hazards of the chemicals prior to the piping supply line change and running the DME process.   Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).