OSHA Inspection: AMERICAN NITRILE OPERATIONS, LLC.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $11,823 · Current $11,823

Hazardous substances 06402260

General-duty citation text

29 CFR 1910.119(d): Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.  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  a. On or about March 18, 2025, the employer failed to document, compile and maintain process safety information concerning the safe upper and lower limits for the chlorine scrubber system, such as, but not limited to, temperatures, pressures, scrubber fluid flow rates or incoming chlorine air stream concentration.   b. On or about March 18, 2025, the employer failed to document, compile and maintain process safety information concerning the safe upper and lower limits for the chlorine system venturi process, such as, but not limited to, temperatures, pressures, chlorine gas flow rates or process water chlorine concentration.  c. On or about March 18, 2025, the employer failed to document, compile and maintain process safety information concerning the safe upper and lower limits for the ventilation system for the chlorine processing room and chlorine storage rooms, such as, but not limited to, temperatures, pressures, flow rates or system exhaust chlorine concentration in air streams transported to the scrubber system.  The lack of documented safe operating limits for covered process equipment can result in equipment failure with loss of containment of chlorine gas and subsequent employee exposure to chlorine inhalation hazards which can result in serious illness or death.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 06402260

General-duty citation text

29 CFR 1910.119(d): Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.  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 18, 2025, the employer failed to document, compile and maintain an evaluation for the consequences of deviations for the following process equipment and systems:  a.	The scrubber system, b.	The chlorine venturi systems, and c.	The chlorine processing and chlorine storage rooms ventilation system.   The lack of documented consequences of deviation evaluations for covered process equipment and systems can result in equipment failure with loss of containment of chlorine gas and subsequent employee exposure to chlorine inhalation hazards which can result in serious illness or death.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 06402260

General-duty citation text

29 CFR 1910.119(d): Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.  29 CFR 1910.119(d)(3)(i):  Information pertaining to the equipment in the process shall include:  29 CFR  1910.119(d)(3)(i)(A): Materials of construction  On or about March 18, 2025, the employer failed to document, compile and maintain the process safety information regarding the materials of construction for the following process equipment and systems:  a. The employer did not document, compile and maintain materials of construction information pertaining to the chlorine scrubber system used to treat and remove chlorine gas from the process stream entering the equipment during normal and emergency operations.   b. The employer did not document, compile and maintain materials of construction information pertaining to components of the ventilation systems, including the systems used for chlorination process dip tanks and the chlorine processing/storage rooms system.   c. The employer did not document, compile and maintain materials of construction information pertaining to safety system components, such as but not limited to gear boxes, auto-closure device armatures/drive shafts, actuators, emergency stops, instrumentation and transmitters, safety PLC and operating systems for the safety systems involved in actuating ton chlorine container valves to control and minimize chlorine gas process hazards.  Failure to document equipment materials of construction can result in underdeveloped process hazard analysis, the inability to perform mechanical integrity activities accurately and compliance gaps with applicable RAGAGEP that can result in equipment-based failures with release of chlorine gas from the covered process.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $7,093 · Current $7,093

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(d)(3)(i): Information pertaining to the equipment in the process shall include:  29 CFR  1910.119(d)(3)(i)(B): Piping and instrument diagrams (P&ID's).  On or about March 18, 2025, the employer failed to document, compile and maintain the equipment in the covered process with complete piping and instrument diagrams.  a. The employer's piping and instrument diagrams (P&IDs) did not individually transition from one diagram (or page) to another within the complete set of P&IDs using specific connector symbol descriptions. Connector symbol descriptions for off-page connectors entering or exiting diagram pages did not include cross referenced connector numbers and P&ID numbers or other P&ID page identification. Examples of P&ID transitions with incomplete connector descriptions include:  1.	The Scrubber duct work flow diagram (page 2) did not include transition information to identify the source description for connection with five PVC pipe/ducts entering the diagram.  2.	The Scrubber 1 Liquid flow diagram (page 3) and Scrubber 2 Liquid flow diagram (page 4) did not include transition information to identify the source description for connection with two 2-inch PVC pipes entering the diagrams and transition information to identify the destination for a two inch PVC pipe exiting the diagrams.  3.	The Chlorinated water flow diagrams (pages 5 and 6) did not include transition information to identify the source description for connection with two 2-inch PVC pipes entering the diagrams, where one 10-inch PVC enters the diagram from and where 1 two inch PVC pipe exits the diagrams.  4.	The Chlorine gas flow diagram (page 7) did not include transition information to identify the source description for connection with six 1-inch PVC pipes exiting the diagram.   b. The employer's piping and instrument diagrams (P&IDs) did not include Chlorine Processing Tanks 3, 4, 5 and 6 located in the chlorine processing room. These tanks are referenced on the Chlorine Gas Flow diagram (page 7) but are not included in the complete set of diagrams.  c. The employer's piping and instrument diagrams (P&IDs) Legend did not detail all symbols and naming conventions used in the diagrams, such as instrumentation tagging and numbering. Information provided by the Legend, or the P&ID Equipment Label page, did not include instrument identification letters or general instrument symbols table(s) to include symbols, such as but not limited to, a square with a diamond inset and a square with a circle inset. Additionally, the "item labels" of the P&ID Equipment Label page did not align with identification information for equipment, such as but not limited to, pressure instrumentation for scrubbers.  d. The employer's piping and instrument diagrams (P&IDs) did not include Utility P&IDs or auxiliary P&IDs for utilities such as, but not limited to, compressed air service, RO (reverse osmosis) water supply, chilled water supply, caustic supply (caustic room) and waste water chlorine.  e. The employer's piping and instrument diagrams (P&IDs) did not include specific symbols for chlorine detection monitoring instrumentation and did not identify specific information for individual detectors in the diagram named Location Drawing (page 8).

Issued

Sep 8, 2025

Abate by

Dec 10, 2025

Penalty

Initial $16,550 · Current $16,550

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(d): Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.  29 CFR 1910.119(d)(3)(i): Information pertaining to the equipment in the process shall include:  29 CFR  1910.119(d)(3)(i)(D): Relief system design and design basis;  On or about March 18, 2025, the employer failed to document relief system design and design basis for the Chlorine scrubber system which was intended by the employer to control chlorine gas released during emergency conditions from covered process equipment, such as storage room located one ton chlorine containers. The employer failed to document:  a. The employer failed to document, compile and maintain information that the scrubber system design included the conditions for the chlorine stream during emergency conditions, the design capacity (the quantity of chlorine that can be scrubbed), the design rate (the chorine processed per unit time including the sodium hydroxide delivery rate), and failed to document that the scrubber was capable of processing the chlorine flow rate of 200 pounds per minute during emergency conditions. The scrubber system design only documented that the scrubber could process 100 ppm of chlorine, which is around 0.11 pounds per minute during normal operations.   b. The employer failed to document, compile and maintain information that the Chlorine scrubber system vents to a safe location. The employer's design and design basis documentation did not address the system venting to a safe location.  c. The employer failed to document, compile and maintain information that the design addressed a multiple relief scenario. The employer's design and design basis documentation did not address multiple container release from a chlorine storage room or a release from both storage rooms, such as during a fire scenario.  Due to this condition, employees have exposure to a scrubber system which is not designed to operate as intended to remove chlorine gas which could result in toxic or respiratory injuries or death from chlorine released from the scrubber during a catastrophic release from the covered process.

Issued

Sep 8, 2025

Abate by

Dec 10, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 06402260

General-duty citation text

29 CFR 1910.119(d): Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.  29 CFR 1910.119(d)(3): Process Safety Information. Information pertaining to the equipment in the process.  29 CFR 1910.119(d)(3)(ii): The employer shall document that equipment complies with recognized and generally accepted good engineering practices.  On or about and prior to March 18, 2025, the employer failed to document compliance with the employer's chosen Recognized and Generally Accepted Good Engineering Practices (RAGAGEP), Chlorine Institute Pamphlet 89, Chlorine Scrubbing Systems, 4th Edition, for the design of the chlorine scrubber system for the chlorine storage and processing rooms. During emergency conditions, such as, but not limited to chlorine release from a 1-ton chlorine cylinder contents due to damage or failure during container loading or unloading operations in the chlorine storage room, or release from container fusible plugs during a fire, the employer failed to document compliance with the employer's chosen RAGAGEP, CI Pamphlet 89 in that:  a.	The employer failed to document compliance with the employer's chosen RAGAGEP, CI Pamphlet 89, Sections 2.4 Overchlorination, 4.7 Controls, and 4.9 Reliability, in that the scrubber system design did not document the methods to prevent, control, or detect the hazards from overchlorination during emergency conditions. Overchlorination can prevent chlorine from being absorbed in the scrubber and cause any overchlorinated solution to release captured chlorine which exposes employees to a scrubber system which is not designed to operate as intended to remove chlorine gas which could result in toxic or respiratory injuries or death from chlorine released from the scrubber.   b.	The employer failed to document compliance with the employer's chosen RAGAGEP, CI Pamphlet 89, Sections 3 Process Considerations and 4 System Design, in that the scrubber system design did not document information such as, but not limited to the conditions for the chlorine stream during emergency conditions, the design capacity (the quantity of chlorine that can be scrubbed), and the design rate (the chorine processed per unit time including the sodium hydroxide delivery rate) to demonstrate that the scrubber was capable of processing the chlorine flow rate of 200 pounds per minute during emergency conditions, and only documented that the scrubber could process 100 ppm of chlorine, which is around 0.11 pounds per minute during normal operations which exposes employees to a scrubber system which is not designed to operate as intended to remove chlorine gas which could result in toxic or respiratory injuries or death from chlorine released from the scrubber.  c.	The employer failed to document compliance with the employer's chosen RAGAGEP, CI Pamphlet 89, Sections 3.1 Characteristics of the Chlorine Stream and 3.4 Heat Effects, in that the scrubber system design did not document that heat effects were addressed during emergency conditions and the methods to prevent overheating. The heat generated can bring the scrubber solution to the boiling temperature and the water vapor generated by the boiling solution dilutes the chlorine and reduces the mass transfer efficiency of the scrubber which exposes employees to a scrubber which is not designed to operate as intended to remove chlorine gas which could result in toxic or respiratory injuries or death from chlorine released from the scrubber.   d. The employer failed to document compliance with the employer's chosen RAGAGEP, CI Pamphlet 89 Sections 2.6.1 Solubility Considerations, 2.6.3 Caustic Acid and Carbon Dioxide and 3.3 Scrubbing Fluid, in that the scrubber system design did not document precautions to avoid and/or accommodate the formation of solids due to freezing, foreign materials, and salt formation which can plug the system which exposes employees to a scrubber system which is not designed to operate as intended to remove chlorine gas which could result in toxic or respiratory injuries or death from chlorine released from the scrubber.   e.	The employer failed to document compliance with the employer's chosen RAGAGEP, CI Pamphlet 89 Sections 3.1 Characteristics of the Chlorine Stream, 4.1 System Design - General, and 4.3 System Design - Chlorine Movers, in that the scrubber system design did not document that materials used in the scrubber system are appropriate for wet chlorine service, which for emergency chlorine scrubbing systems the conservative system design assumes, or that the expected service during an emergency service would be dry which is not designed to operate as intended to remove chlorine gas which could result in toxic or respiratory injuries or death from chlorine released from the scrubber.  Failure to document compliance with the employer's chosen RAGAGEP, CI Pamphlet 89, 4th Edition, for the design for the chlorine scrubber system exposes employees to a scrubber system that may not operate as intended which could result in toxic or respiratory injuries, or death, due to exposure to chlorine released from the scrubber.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $11,823 · Current $11,823

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(d): Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.  29 CFR 1910.119(d)(3)(i): Information pertaining to the equipment in the process shall include:  29 CFR  1910.119(d)(3)(i)(E): Ventilation system design;  a. On or about March 18, 2025, the employer failed to document, compile and maintain process safety information (PSI) regarding the ventilation system's design for the chlorine gas storage rooms and chlorine processing room. The employer's PSI documentation did not include the ventilation system design for both normal and emergency ventilation, to include, but not limited to, calculations for the maximum rate that the ventilation system exhausts during emergency release of chlorine and calculations for the rate during normal operations used for the system design.   Due to this condition, ventilation system failure in chlorine rooms could result in the accumulation of chlorine gas during a release, potentially exposing employees to chemical burns and inhalation hazards.

Issued

Sep 8, 2025

Abate by

Dec 10, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(d): Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.  29 CFR 1910.119(d)(3)(i): Information pertaining to the equipment in the process shall include:  29 CFR 1910.119(d)(3)(i)(H): Safety systems (e.g. interlocks, detection or suppression systems).  a. On or about, and prior to, March 18, 2025, the employer failed to document, compile and maintain process safety information (PSI) regarding safety systems associated with the chlorine storage rooms and chlorine processing room to detect chlorine gas, provide alarms and control exhaust ventilation to transport released gas to the scrubber system. The employer failed to document a detailed description of the safety system(s), the safety system design, process control logic and system logic diagrams, any hazard analysis associated with the system design, equipment installation documentation to include identification by type, make/model/serial number for safety system components, original acceptance testing/commissioning documentation and testing procedures for system performance. Safety systems utilized in the chlorine covered process include interlocked auto-closure devices used for ton container valve closure, valves, control devices, instrumentation, transmitters, software, control/operating system hardware, alarms, and emergency stops.

Issued

Sep 8, 2025

Abate by

Dec 10, 2025

Penalty

Initial $16,550 · Current $16,550

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(e)(3): The process hazard analysis shall address:  29 CFR 1910.119(e)(3)(i): The hazards of the process.  On or about March 18, 2025, chlorine gas hazards were not addressed during process hazard analysis (PHA), such as, but not limited to:   a. For the 2022 PHA, the PHA did not address Scrubber System failure due to input stream containing chlorine gas that exceeds the design criteria of 100 ppm during abnormal or emergency conditions. The PHA did not include a Node for the Scrubber System which is intended to remove chlorine gas by reacting with sodium hydroxide for both normal and abnormal (or emergency) conditions. Scrubber system failure can result in catastrophic release of chlorine gas from the covered process.   b. For the 2022 PHA, the PHA did not address Scrubber System failure due to loss of scrubbing fluid flow, loss of sodium hydroxide flow or consumption of sodium hydroxide in scrubbing fluid due to overchlorination. The PHA did not include a Node for the Scrubber System which is intended to remove chlorine gas by reacting with sodium hydroxide for both normal and abnormal (or emergency) conditions. Scrubber system failure can result in catastrophic release of chlorine gas from the covered process.   c. For the 2022 PHA, the PHA did not address Scrubber System failure due to heat effects or solubility (formation and precipitation of solids) effects impacting the scrubbing performance. The PHA did not include a Node for the Scrubber System which is intended to remove chlorine gas by reacting with sodium hydroxide for both normal and abnormal (or emergency) conditions. Scrubber system failure can result in catastrophic release of chlorine gas from the covered process.   d. For the 2022 PHA, the PHA did not address Scrubber System failure due to loss of air flow from blower motor failure or decreased blower motor performance. The PHA did not include a Node for the Scrubber System which is intended to remove chlorine gas by reacting with sodium hydroxide for both normal and abnormal (or emergency) conditions. Scrubber system failure can result in catastrophic release of chlorine gas from the covered process.   e. For the 2022 PHA, the PHA node for Chlorine Ton Container Receiving, Hook Up, Disconnect and Container Return, What If Deviation "What if the Ton Container is dropped Inside of the Chlorine Room" did not address a dropped container striking another container or auto-closure device equipment, damaging the equipment resulting in failure and chlorine gas release from damaged equipment. The consequence for this What If Deviation was blank and failed to include chlorine release due to a material handling drop of a container.   f. For the 2022 PHA, the PHA node for Ton Container to Water Tank did not address hazards with eductor failure for the Venturi addition of chlorine gas into the process water flow from Chlorine Processing Tanks. This node had six lines addressing Parameter "Flow" listing Guide Word "High" with Deviation "Line or Equipment Failure," five lines Parameter "Flow" listing Guide Word "Low" with no listed Deviation and one line with Parameter "Pressure" listing Guide Word "High" that did not address eductor failure as either a consequence or a cause. Eductor failure can result in process hazards that include increased corrosion on equipment due to mixing effects and catastrophic release of chlorine gas from the covered process.   g. For the 2022 PHA, the PHA failed to address hazards associated with valve misalignment for the analysis of process equipment and process equipment flows. Valve misalignment can lead to flow loss, unintended flows of process materials including chlorine gas, increased flow and improper mixing. The only PHA line that included valve misalignment did not list a hazard or Deviation; in that the PHA node for Ton Container to Water Tank line with the Parameter "Flow" listing Guide Word "Low" then a Cause detailed as "Valve not open all way" did not include a hazard when the Deviation was left blank. An example of unaddressed valve misalignment hazards for the PHA includes, but is not limited to, loss of chlorine process water flow from Processing Room tanks resulting in Chlorine gas flow into the chlorine process water piping that leads to the production line dip tanks.   h. For the 2022 PHA and the 2024 PHA, the PHAs failed to address hazards associated with a power outage impacting the function covered process equipment and controls involved with preventing the release of chlorine gas from the covered process. The 2024 PHA which focused on human factors, line item 8, and the 2022 PHA Facility Siting section, line item 8, only addressed emergency lighting and available backup power for lighting, and then did not address hazards associated with a power outage impact on covered process equipment and controls.  i. For the 2022 PHA, the PHA lacked specificity when addressing process piping leaks. For the process Node, "Chlorinated Water from the Water Tank to Glove Vat," the line item with Parameter "Flow" Guide Word "High" listed "Various scenarios" as the cause for process piping leak. The hazard and location of the hazard lacked specificity to analyze the risk, analyze and apply controls that address the specific hazard and assure the controls claimed prevent the piping leak or minimize the impact of leaks from process piping in the covered process.  The failure of process hazard analysis to address process hazards for a chlorine gas covered process can lead to catastrophic release of chlorine from the process which can result in permanent lung damage or death for employees from inhalation hazards.

Issued

Sep 8, 2025

Abate by

Dec 10, 2025

Penalty

Initial $16,550 · Current $16,550

Hazardous substances 06402260

General-duty citation text

29 CFR 1910.119(e)(3): The process hazard analysis shall address:  29 CFR  1910.119(e)(3)(iii): Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.);  On or about March 18, 2025, engineering and administrative controls applicable to chlorine gas hazards and their interrelationships with chlorine gas hazards were not addressed during process hazard analysis (PHA), such as, but not limited to:  a. For the 2022 PHA, the claimed control, "Scrubber inter lock to CL2 Closure Devices," lacked specificity, was not a process safety information documented control or did not exist for the PHA Node "Chlorinated Water from the Water Tank to Glove Vat" line with Parameter "Pressure," Guide Word "High" for the Deviation "Chlorine Release from Water to work area" and Cause "Scrubber Failure." A scrubber system interlock to chlorine container closure devices did not exist and was not described in process safety information for safety systems involving chlorine container closure devices or the scrubber system. Additionally, a piece of equipment cannot be claimed to prevent, or control the release  from a piece of equipment that itself has failed in an appropriately applied hazard analysis.  b. For the 2022 PHA, the PHA did not consider process monitoring and control instrumentation for scrubbing fluid flow rates in Scrubber Systems to address chlorine gas hazards associated with the loss of scrubbing capacity. Loss of adequate scrubbing fluid flow in either normal or emergency conditions, can lead to incomplete removal of chlorine gas during processing of system inlet streams and chlorine gas release from the covered process.  c. For the 2022 PHA, the PHA did not consider process monitoring and control instrumentation for sodium hydroxide content levels or concentration in scrubbing fluid for Scrubbing Systems. Reduced sodium hydroxide levels in scrubbing fluid can lead to incomplete removal of chlorine gas during processing of system inlet streams and chlorine gas release from the covered process.  d. For the 2022 PHA, the PHA did not consider Scrubber System process monitoring and control instrumentation for inlet chlorine stream ductwork to monitor concentration of chlorine gas and adjust system parameters to avoid loss of scrubbing. Monitoring of the chlorine levels in the stream entering the scrubber inlet can provide detection that chlorine levels exceed system settings for normal  operations and allow controls to adjust system parameters, such as increasing sodium hydroxide scrubbing solution flow, to assure effective processing to remove chlorine gas from the scrubber system. Monitoring ductwork for chlorine levels and using system controls to increase scrubbing capacity are interrelated controls that can prevent release of chlorine gas from the scrubber system.  e. For the 2022 PHA, the PHA failed to address hazards associated with leaks from process piping in that the engineering and administrative controls claimed lacked specificity. The PHA node "Chlorinated Water from the Water Tank to Glove Vat" line item with Parameter "Flow" Guide Word "High" and listed the Deviation "Leak of chlorinated water line" with Causes listed as "Various scenarios" listed controls as Safeguards that lacked specificity to the hazards associated with piping leaks. Safeguards listed included procedures, training, solubility of chlorine in water, and past history and PM of line and ancillary equipment. The listed controls did not include and address what specific procedures applied to piping leaks hazards, how procedures applied to controlling leaks from process piping, did not include the specific training that applied to piping leaks hazards, how the training applied to controlling or minimizing risk from piping leaks, did not address or specify how solubility and past history applied, the interrelationship with past history preventing piping leaks for "various scenarios" causing leaks, and which PMs applied to controlling piping leaks, or which PMs applied to "ancillary equipment." Additionally, the listing did not specify what specific equipment was being considered as "ancillary equipment" in the PMs referenced as controls in the Safeguards listing.  The failure of process hazard analysis to address engineering controls for all the process hazards of a chlorine gas covered process can increase the risk for catastrophic release of chlorine from the process which can result in permanent lung damage or death for employees from inhalation hazards.

Issued

Sep 8, 2025

Abate by

Dec 10, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(e)(3): The process hazard analysis shall address:  29 CFR  1910.119(e)(3)(v): Facility siting;  On or about March 18, 2025, process hazards were not addressed during Facility Siting process hazard analysis, such as, but not limited to:  a. For the 2022 PHA that addressed Facility Siting, the PHA Facility Siting Analysis, Section I - Spacing between Units and Process Vessels, line item 5, introduced fire scenario hazards without addressing chlorine gas release in a multi-relief scenario occurring in the storage rooms. The hazard analysis did not address hazards from multiple ton containers releasing chlorine gas simultaneously in the event of fire in the storage room.  b. For the 2022 PHA that addressed Facility Siting, the PHA did not address the hazards for chlorine gas from Scrubber System relief ductwork re-entering the facility. The PHA did not address facility siting hazards related to the location of vent ductwork, such as chlorine gas venting from Scrubber System rooftop located ductwork, to prevent chlorine gas from potentially entering the building HVAC make-up air or entering the building through other openings in the structure.  c. For the 2022 PHA that addressed Facility Siting, the PHA Facility Siting Analysis, Section XIII - Contingency Planning, line item 3, claimed calculations, charts, and other documents that verified normal direction and wind velocity, atmospheric dispersion of chlorine gas (which is heavier than air) and potential radiant heat density conditions during a fire, was not documented for consideration by the PHA team during hazard analysis. Process Safety Information for the chemical, technology of the process, for the equipment in the process and the emergency action plan did not include this documentation.  d. For the 2022 PHA that addressed Facility Siting, the PHA Facility Siting Analysis, Section XIII - Contingency Planning, line item 11, claimed that evacuation plans were adequate, even though the company's emergency action plan was not compliant. The company emergency action plan did not document and detail the procedures for notification of a chlorine release, details for evacuation from a chlorine release and did not include the specific audible alarm for chlorine gas release related evacuation in emergency procedures (see citation 1 item 14.)  Failure to address Facility Siting and Facility Siting hazards in process hazard analysis can result in increased risk for catastrophic release of chlorine gas from the company covered process with chlorine inhalation related injury and/or death to exposed employees.

Issued

Sep 8, 2025

Abate by

Dec 10, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(e)(3): The process hazard analysis shall address:  29 CFR  1910.119(e)(3)(vi): Human factors  a. On or about March 18, 2025, for the 2024 process hazard analysis (PHA), the PHA Human Factors checklist claimed that warning signs were easily understood when signs on the storage room doors indicated safe entry below 25 ppm chlorine and windsocks mentioned in this line item were not adequately addressed in the emergency action plan. The PHA, Section I - Housekeeping and General Work Environment, line item 1, Section III - Labeling, line item 5, claimed credit for easily understood warning signs when entry into the storage room under sign conditions could expose employees to chlorine gas hazards. Entry into the storage room under sign conditions could expose employees who entered above the OSHA permissible exposure limit as a Ceiling of 1 ppm, could allow entry into IDLH conditions (Imminently Dangerous to Life and Health) at 10 ppm and did not suggest or include any personal protective equipment requirements for entry. The PHA, Section I - Housekeeping and General Work Environment, line item 1, and Section III - Labeling, line item 5, mentioned windsocks installation when the warning sign was not easily understood. The company emergency action plan (EAP) then included the windsocks in the plan discussions of designated rally points without any instruction on the windsocks use, how to use windsocks visually to determine impact on chlorine release from rooftop ductwork, and how to relocate due to wind patterns reflected by windsocks. The Human Factors checklist claimed signage as easily understood when human factors can lead to increased risk for chlorine exposure to employees due to the lack of this hazard being adequately addressed by the PHA.  b. On or about March 18, 2025, for the 2024 PHA, the PHA Human Factors checklist claimed that automatic safety features provided feedback in displays when the process conditions for Scrubber System chlorine stream processing did not address emergency conditions when system design for normal operations was exceeded. The PHA Human Factors, Section IV- Feedback/Displays, line item 6, Question: "Are automatic safety features provided when a process upset may be difficult to diagnose due to complicated processing of various information" claimed that such features were provided for the covered process Scrubber System/emergency relief system when no such features are provided to ensure that emergency conditions, such as uncontrolled release of chlorine gas from a damaged ton chlorine container, would not exceed Scrubber System design for scrubbing capacity and would automatically provide increased scrubber capacity.  c. On or about March 18, 2025, for the 2024 PHA, the PHA Human Factors checklist, Section VII - Procedures, claimed that written procedures existed for all operating phases when procedures were not in place for Scrubber Systems normal operations and were not in place for Scrubber Systems emergency operations. In addition, existing procedures did not include clear steps for emergency shutdown, when evacuation is to occur in Chlorine Processing operating procedures, failed to include when emergency shutdown should occur in Scrubber Systems emergency shutdown procedures, and in general did not include operating limits, the steps to prevent deviation from operating limits, and the consequences of deviation from operating limits in Scrubber System operating procedures. The PHA claimed procedures for all phases of operation when procedures for phases did not exist and procedures that did exist lacked functional compliant content required by 29 CFR 1910.119(f).  d. On or about March 18, 2025, for the 2024 PHA, the PHA Human Factors checklist, Section VII - Procedures, claimed that safe operating limits and consequences of deviation were documented in procedures, when the company had not documented this required process safety information (see citation 1 Items 1a and 1b) or included the information in operating procedures for the Scrubber System.  e. On or about March 18, 2025, for the 2024 PHA, the PHA Human Factors checklist Section VIII - Training claimed that employees receive training when changes are made when the employer does not implement PSM management of change procedures. The company had not performed or documented an PSM Management of Change procedures (MOC) and had not performed any training for MOC related required process safety information updates, required changes to operating procedures or any MOC related impacts on safety and health.  Failing to address human factors and the impact of human factors on process hazards during PHAs can increase the risk for catastrophic release of chlorine gas from the covered process and result in employee exposure to chlorine inhalation hazards that can lead to permanent injury or death.

Issued

Sep 8, 2025

Abate by

Dec 10, 2025

Penalty

Initial $16,550 · Current $16,550

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(e)(3): The process hazard analysis shall address:  29 CFR  1910.119(e)(3)(iv): Consequences of failure of engineering and administrative controls;  On or about March 18, 2025, the failure of engineering and administrative controls and the consequence of control failure for chlorine gas hazards were not addressed during process hazard analysis (PHA), such as, but not limited to:  a. For the 2022 PHA, the PHA failed to address the consequences for Scrubber System failure, such as a catastrophic release from the covered process. PHA Nodes for "Chlorine Ton Container Receiving, Hook Up, Disconnect and Container Return" and "Ton Container to Water Tank" addressed chlorine gas hazards and claimed the Scrubber System as a control in 16 separate PHA line items for these Nodes without addressing the failure of the claimed engineering control as a hazard analysis consideration. Additionally, a line item included by the PHA node "Chlorinated Water from the Water Tank to Glove Vat" listed Cause "Scrubber Failure" for chlorine gas release from dip tank water on the production line but did not effectively address further consequences of failure. At the same time, the Scrubber System was also claimed as a control in preventing the system's own failure.  b. For the 2022 PHA, the PHA failed to address the consequences for chlorine detection instrumentation failure. The PHA addressed chlorine detection in 19 separate line items as a control for chlorine gas hazards. The PHA does not address the consequences of or the failure of chlorine detection instrumentation in hazard analysis.  c. For the 2022 PHA, the PHA failed to address the consequences for chlorine container auto-closure device and associated safety system failure. The PHA addressed chlorine container closure devices in 12 separate line items as a control for chlorine gas hazards. The PHA does not address the consequences of or the failure of chlorine container auto-closure device safety systems in hazard analysis.  d. For the 2022 PHA, the PHA failed to address the consequences for chlorine storage room/chlorine processing room ventilation system failure. The PHA addressed the chlorine storage room/processing room ventilation system in 12 separate line items as a control for chlorine gas hazards. The PHA does not address the consequences of, or the failure of chlorine storage room ventilation systems in hazard analysis.  Failure of engineering controls, such as safety system components, the chlorine Scrubber System and ventilation systems, can lead to release of chlorine gas from the covered process which can result in permanent lung damage or death for employees from inhalation hazards.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $11,823 · Current $11,823

Hazardous substances 0640

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 following elements.  29 CFR 1910.119(f)(1)(i): Steps for each operating phase:  29 CFR  1910.119(f)(1)(i)(B): Normal operations;  On or about March 18, 2025, the employer failed to develop and implement written operating procedures that provided clear step by step instructions for safely conducting normal operations, in that:  a. The Chlorine Handling procedure, S.5.Plant Operating Procedures and practice Chlorine Handling, did not address the use of material handling equipment for the movement of one ton chlorine containers from the chlorine compound storage rack into the chlorine storage room(s) for positioning and connection to the container manifold, and for removing used containers from the room into the chlorine compound storage rack.  b. The Chlorine Handling procedure, S.5.Plant Operating Procedures and practice Chlorine Handling, Section 2.4 Chlorine Ton Container Changeover instructions, did not address the air supply for the auto-closure device motor, auto-closure device components, shutoff arm (drive shaft) and gear box, use of the trap key, use of the chlorination wrench, and use of the HMI panel "reset" in for container disconnecting and connecting from the Chlorine Storage room supply system header. During container changeover, operational steps for disconnecting and then connecting safety system components for the valve auto-closure device were not included, operational steps for trap key use for the safety system were not included, the use of the specific wrench for disconnection/connection of the chlorine containers and the use of the HMI panel reset were not addressed.   c. Work Instruction, WI-ENG-113-C-3 Scrubber Operations, did not provide clear instructions for the step by step operation during normal operating conditions of the Chlorine Scrubber system used to remove chlorine gas from inlet streams entering the equipment. The five page procedure addressed Scrubber Startup in Section 6.1, Scrubber Shutdown in Section 6.2, Emergency Shutdown in Section 6.3, and did not contain a section on Normal Operations.  d. Work Instruction, WI-ENG-113-C-4 Chlorine Systems Adjustments and Troubleshooting and Supply Room Changeover, lacked specificity and did not provide clear instructions for the step by step operation during normal operations of the chlorination system involving the ongoing injection of chlorine gas into process water used for glove treatment in production line dip tanks. The four page procedure addressed common adjustments in Section 6 with two sentences addressing the chlorinated water processing room rotameter but did not include chlorine gas flow rate(s) under normal operating conditions, did not provide clear instructions for conditions triggering adjustments of chlorine gas flow rates using the rotameter, and did not include any information regarding the use of chlorination HMI for evaluating conditions related to common adjustments made during normal operations. The four-page procedure addressed troubleshooting in Section 7 but lacked specificity regarding dip tank chlorine concentration, lacked specificity regarding flow meter "float" use in troubleshooting chlorine container content levels, lacked specificity in monitoring pressure readings and chlorine content in chlorinated water, and lacked specificity on alarms and devices with alarm conditions impacting chlorine gas flow. Section 8, Chlorine Supply Room Changeover, addresses procedures for temporary operations that idle chlorination while transitioning between chlorine gas sources but did not address normal chlorination operations.  Failure to develop safe operating procedures for normal operations can result in release of chlorine gas from the covered process resulting in employee exposure to inhalation hazards with potential for permanent lung damage and death.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0640

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 following elements.  29 CFR 1910.119(f)(1)(i): Steps for each operating phase:  29 CFR  1910.119(f)(1)(i)(D): Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner.  On or about March 18, 2025, the employer failed to develop and implement written operating procedures that provided clear step by step instructions for safely conducting emergency shutdown, in that:  a. The Chlorine Handling procedure, S.5.Plant Operating Procedures and practice Chlorine Handling, did not include the conditions under which emergency shutdown is required and did not address the actions employees must take to ensure the shutdown is executed in a safe manner. Step 2.6.1 of the procedure lacked specificity and did not include the conditions under which emergency shutdown is required. Step 2.6.2 failed to describe actions employees should take regarding evacuating the storage room once an emergency shutdown has been initiated, lacks specificity regarding how employees monitor chlorine concentration in the storage room after the emergency shutdown button has been pushed to initiate emergency shutdown, and lacks specificity for employees addressing caustic soda in the scrubber system.  b. The work instruction WI-ENG-113-C-3 Scrubber Operations, Section 6.3 Emergency Shutdown, did not include conditions under which an emergency shutdown is required.  c. The employer failed to develop written operating procedures for an emergency shutdown of the chlorination process.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0640

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 following elements.  29 CFR 1910.119(f)(1)(i): Steps for each operating phase:  29 CFR  1910.119(f)(1)(i)(E): Emergency Operations;  On or about March 18, 2025, the employer failed to develop and implement written operating procedures that provided clear step by step instructions for safely conducting emergency operations, in that:  a. The employer failed to develop and implement a written emergency operations operating procedure for the Scrubber Systems. The employer's existing written procedure, Work Instruction WI-ENG-113-C-3 Scrubber Operations, did not address emergency operations. The work instruction did not provide clear instructions for operational steps during emergency operations when the system is used to remove chlorine gas from inlet streams entering the equipment, such as from the storage room ventilation system. The Chlorine scrubber system is intended to operate during chlorine emergencies, such as a release of contents from one ton chlorine containers connected to a header in the Chlorine storage room(s) that supplies chlorine gas to the chlorination process.  b. The Chlorine Handling procedure, S.5.Plant Operating Procedures and practice Chlorine Handling, did not provide clear instructions regarding caustic soda levels in the scrubber system. Step 2.6.2 of the procedure lacked specificity when instructing employees to ensure caustic soda levels are adequate in the scrubbers to prevent overchlorination due to chlorine release from ton containers in the storage room.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0640

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 following elements.  29 CFR 1910.119(f)(1)(i): Steps for each operating phase:  29 CFR  1910.119(f)(1)(i)(F): Normal shutdown  On or about March 18, 2025, the employer failed to develop and implement written operating procedures that provided clear step by step instructions for safely conducting normal shutdown, in that:  a. The Chlorine Handling procedure, S.5.Plant Operating Procedures and practice Chlorine Handling, did not include clear instructions for the steps for normal shutdown. Section 2.7 Non-Emergency Shut Down lacked specificity in step 2.7.1 in that the procedure for handling ton containers did not include instructions on how to pull vacuum with the venturi injector, lacked specificity regarding valve closure location, and did not specify the pressure level reduction necessary for valve closure.  b. The company did not develop written operating procedures for a normal shutdown of the chlorination process.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $11,823 · Current $11,823

Hazardous substances 0640

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 following elements.  29 CFR 1910.119(f)(1)(ii): Operating limits:  29 CFR  1910.119(f)(1)(ii)(A): Consequences of deviation.  On or about March 18, 2025, the employer failed to develop and implement written operating procedures that provided clear step by step instructions for safely conducting operations which address operating limits and the consequences for deviation from operating limits, in that:  a. The Chlorine Handling procedure, S.5.Plant Operating Procedures and practice Chlorine Handling, did not include consequences of deviation for performing steps out of sequence during start-up. In Section 2.7.2, the consequences for opening chlorine valves prior to initiating water flow through the venturi injector was not addressed for "restart" or normal startup.  b. The work instruction WI-ENG-113-C-3 Scrubber Operations, failed to include consequences of deviation for the scrubber system operating limits for parameters such as, but not limited to, temperature increase, caustic solution concentration, caustic solution flow rate, pH, and inlet chlorine gas concentration. The work instruction included startup, shutdown, and emergency shutdown sections, which did not address or include instructions regarding consequences of deviation for the Chlorine scrubber system used to remove chlorine gas from inlet streams entering the equipment, such as from the storage room ventilation system.  c. The Chlorine Handling procedure, S.5.Plant Operating Procedures and practice Chlorine Handling, did not include consequences of deviation for container leak testing. The procedures for leak testing in Section 2.4, Chlorine Ton Container Changeover, lacked specificity for the vapor use and did not address ammonium hydroxide solution contacting components of the container during testing.  d. The work instruction, WI-ENG-113-C-4, Chlorine Systems Adjustments and Troubleshooting and Supply Room Changeover, did not include consequences of deviation from operating limits. The procedure did not include any operating limits for flow rate, chlorine concentration, or pressure. The procedure addressed the chlorine gas flow rate in Section 6 without addressing the consequences of deviation regarding flow rate. The procedure addressed chlorine concentration in dip tanks, chlorinated process water flow rate, and gas pressure in Section 7 without addressing the consequences of deviation for these parameters  Failure to address consequences for deviation from operating limits in operating procedures can result in catastrophic failure of process equipment and release of chlorine gas from the covered process.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0640

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 following elements.  29 CFR 1910.119(f)(1)(ii): Operating limits:  29 CFR  1910.119(f)(1)(ii)(B): Steps required to correct or avoid deviation.  On or about March 18, 2025, the employer failed to develop and implement written operating procedures that provided clear step by step instructions for safely conducting operations addressing operating limits and the steps to correct or avoid deviation, in that:  a. The Chlorine Handling procedure, S.5.Plant Operating Procedures and practice Chlorine Handling, did not address the steps to correct or avoid deviation during emergency shutdown related to exceeding scrubbing capacity. Section 2.6 emergency shutdown does not include steps to ensure excess sodium hydroxide scrubber solution is used to prevent overchlorination of the scrubber and prevent release of chlorine from the scrubber system.  b. The Chlorine Handling procedure, S.5.Plant Operating Procedures and practice Chlorine Handling, did not address the steps to correct or avoid deviation for Chlorine Ton Container Changeover and potential chlorine leaks from equipment connections. Section 2.4, steps 7 through 10, address leaks, leak detection, and leak correction during equipment connection but did not address steps to take if connection issues are unable to be corrected.   c. The work instruction WI-ENG-113-C-3 Scrubber Operations, failed to include clear instructions for the operational steps to correct or avoid deviation for scrubber system operation parameters, such as, but not limited, to fresh water, blower speed, caustic soda dosing, minimum pH, and the pH deadband, which are listed in Section 6.1. The Scrubber Operations work instruction did not include clear instructions regarding safe operating limits and failed to include steps to correct or prevent deviations related to loss of air flow, loss of fresh water flow, and reduced caustic soda levels below safe operating limits, or for not maintaining pH at safe levels for processing chlorine gas. In addition, the procedure did not address steps to correct deviation for reduced scrubber fluid flow and reduced scrubbing fluid sodium hydroxide concentration.  Failure to include clear instruction for correcting or preventing process deviation can result in employee exposures to chlorine gas during the performance of chlorine container handling or from the catastrophic release of chlorine gas from the covered process due to scrubber failure.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $11,823 · Current $11,823

Hazardous substances 0640

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 following elements.  29 CFR  1910.119(f)(1)(iii): Safety and health considerations:  29 CFR  1910.119(f)(1)(iii)(A): Properties of, and hazards presented by, the chemicals used in the process;  On or about March 18, 2025,the employer failed to develop and implement written operating procedures that provided clear step by step instructions for safely conducting operations addressing safety and health considerations and the properties of and hazards presented by the chemicals used in the process, in that:  a. The company work instruction, WI-ENG-113-C-3 Scrubber Operations, did not include and address the hazards related to sodium hydroxide and chlorine gas in the Chlorine scrubber system. Hazards related to these chemicals include contact hazards, inhalation hazards, and process hazards related to chemical reaction in the system, including heat effects and overchlorination. Employee exposure to these chemicals can result in chemical burns from contact with sodium hydroxide and death from inhalation of chlorine gas.  b. The company work instruction, WI-ENG-113-C-4 Chlorine System Adjustments and Troubleshooting and Supply Room Changeover, did not include and address the hazards related to chlorine use in the covered process. Hazards related to chlorine include contact hazards, inhalation hazards and process hazards related to injection into process and chemical reaction in the scrubbing. Employee exposure to these chemicals can result in chemical burns from potential contact with liquid chlorine from leaks and death from inhalation of chlorine gas from a catastrophic release.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 06402260

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 following elements.  29 CFR 1910.119(f)(1)(iii): Safety and health considerations:  29 CFR  1910.119(f)(1)(iii)(B): Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment;  On or about March 18, 2025, the employer failed to develop and implement written operating procedures that provided clear step by step instructions for safely conducting operations that addressed the safety and health considerations for the precautions necessary to prevent exposure, in that:  a. The employer's work instruction, WI-ENG-113-C-3 Scrubber Operations, failed to include personal protective equipment as part of clear instructions to address precautions necessary to prevent exposure to sodium hydroxide. Section 6.1 addresses operating procedures for scrubber startup, including instructions that require employees to verify inlet and outlet side valve positioning for circulation pumps. During scrubber startup and other operational activities, employees have potential exposure to contact hazards associated with sodium hydroxide from equipment leaks or failure that can result in chemical burns.  b. The employer's work instruction, WI-ENG-113-C-4 Chlorine Systems Adjustments and Troubleshooting and Supply Room Changeover, failed to include personal protective equipment as part of clear instructions to address precautions necessary to prevent exposure to chlorine gas. The instruction did not include protective equipment required by the employer for entry into storage and processing rooms during chlorine injection operations as part of the chlorination process which includes respiratory protection and hand protection. During Supply Room Changeover, procedural step 8.4 includes instructions that require employees to enter the Chlorine processing room to operate valves directing chlorine gas flow as part of the procedures. During Chlorine processing room entry, employees have potential exposure to inhalation hazards associated with chlorine gas from equipment leaks or failure that can result in permanent lung damage or death.  c. The employer's work instruction, WI-ENG-01-08 POWER OUTAGE RESTARTING INSTRUCTIONS, failed to include personal protective equipment (electrical) as part of clear instructions to address precautions to protect against electrical contact hazards in dipping tank panels. During process restart after a power outage, procedures 7.2.1 through 7.2.3 include instructions for resetting dipping tank equipment that involve opening live electrical panels to press reset buttons for motor drive controls. During activity in live electrical panels, such as initiating motor drive reset, employees have exposure to electrical hazards, including shock and potential electrocution.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 06402260

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 following elements.  29 CFR 1910.119(f)(1)(iii): Safety and health considerations:  29 CFR  1910.119(f)(1)(iii)(C): Control measures to be taken if physical contact or airborne exposure occurs;  a. On or about March 18, 2025,  the employer's operating procedures did not include clear instructions and address the considerations to be taken if physical contact or airborne exposure occurs with sodium hydroxide, liquid chlorine, or chlorine gas. Operating procedures that do not address measures to be taken regarding sodium hydroxide and/or chlorine physical contact or airborne exposure occurrences include work instructions, WI-ENG-113-C-4 Chlorine Systems Adjustments and Troubleshooting and Supply Room Changeover, WI-ENG-113-C-3 Scrubber Operations, WI-ENG-01-08 POWER OUTAGE RESTARTING INSTRUCTIONS, and The Chlorine Handling procedure, S.5.Plant Operating Procedures and practice Chlorine Handling.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $11,823 · Current $11,823

Hazardous substances 0640

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 following elements.  29 CFR  1910.119(f)(1)(iv): Safety systems and their functions.  On or about March 18, 2025, the employer failed to develop and implement written operating procedures that provided clear step by step instructions for safely conducting operations addressing safety systems and their function, in that:  a. The Chlorine Handling procedure, S.5.Plant Operating Procedures and practice Chlorine Handling, did not include and failed to address the safety system for the automated valve closing equipment for one ton containers in the Chlorine storage rooms. Each cylinder is controlled by the safety system and is fitted with a pneumatically operated valve closure device that is triggered to close by chlorine detection instrumentation.   b. The Chlorine Handling procedure, S.5.Plant Operating Procedures and practice Chlorine Handling, did not include and failed to address the safety system that includes automated damper control for the Chlorine storage room(s) ventilation system operation. Each storage room contains chlorine detection that triggers the opening of a damper in ventilation system ductwork to increase flow from the storage rooms into the Chlorine scrubber system. This safety system component is intended to remove Chlorine gas from the storage room(s) by transporting the gas through ventilation system ductwork for gas removal by the Chlorine scrubber system.  c. The work instruction WI-ENG-113-C-3, Scrubber Operations did not include and failed to address the safety system that includes ventilation system branches transporting chlorine gas to the scrubbing system from a chlorine gas release. Each storage room contains chlorine detection that triggers safety system operation of dampers in ventilation system ductwork to increase flow from the storage rooms through a ventilation system to remove chlorine gas during emergency conditions. This safety system is intended to remove Chlorine gas from a release by transporting the gas through ventilation system ductwork for gas removal by the Chlorine scrubber system  d. The work instruction WI-ENG-113-C-4, Chlorine Systems Adjustments and Troubleshooting and Supply Room Changeover did not include and failed to address the Chlorine storage room(s) safety system(s). Each storage room contains chlorine detection that triggers the opening of a damper in ventilation system ductwork to increase flow from the storage rooms into the Chlorine scrubber system. This safety system component is intended to remove Chlorine gas from the storage room(s) by transporting the gas through ventilation system ductwork for gas removal by the Chlorine scrubber system. Chlorine detection in storage rooms also triggers safety system controlled auto-closure devices for ton chlorine container valves.  The employer's safety systems are used to control chlorine gas release and hazards associated with release that include sending chlorine gas to scrubber system equipment. Failure to integrate safety system information into operating procedures can result in release of chlorine gas from the covered process during emergency conditions, such as scrubber system failure which can result in employee exposure to inhalation hazards from a catastrophic release. .

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $11,823 · Current $11,823

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(i): Pre-startup safety review.  29 CFR 1910.119(i)(2): The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process:  29 CFR  1910.119(i)(2)(ii): Safety, operating, maintenance, and emergency procedures are in place and are adequate;  a. On or about March 18, 2025, the employer failed to perform a required pre-startup safety review that included a review to ensure operating, maintenance, and emergency procedures were in place and adequate when production was expanded to include a second chlorine-based production line and when safety system components were upgraded with the installation of a safety PLC (programmable logic controller). These process modifications involved the need to update process safety information. The employer failed to review procedures as part of a pre-startup safety review and multiple operating procedures lack OSHA PSM standard required content (see Citation 1 Items 8 a-d, 9 a-b and 10 a-c), maintenance procedures for mechanical integrity lacked content (see Citation 1 Items 13 b - c), and neither the emergency action plan or incident management system directly addressed a chlorine release from the covered process. Due to the employer not reviewing procedures as part of a pre-start up safety review, employees were at increased risk from inhalation injury/illness related to a catastrophic chlorine release from the covered process.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR 1910.119(l): Management of change.  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.  a. On or about March 18, 2025, the employer failed to implement Management of Change procedures for changes to equipment that affect the chlorine based covered process, including, but not limited to, the increase of production by introducing a second chlorine based production line and the update to the safety PLC (programmable logic controller) that is part of the safety system controlling chlorine detection based safety components in the safety system. For the changes affecting the covered process, the employer failed to address the considerations listed in 29 CFR 1910.119(l)(2)(i)-(v), inform and train employees affected by the change in accordance with 29 CFR 1910.119(l)(3), document and update process safety information involved with the change in accordance with 29 CFR 1910.119(l)(4), and update operating procedures in accordance with 29 CFR 1910.119(l)(5).

Issued

Sep 8, 2025

Abate by

Dec 10, 2025

Penalty

Initial $16,550 · Current $16,550

Hazardous substances 06402260

General-duty citation text

29 CFR  1910.119(j): Mechanical integrity.  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.  a. On or about March 18, 2025, the employer's mechanical integrity (MI) procedures for the Scrubber system did not include a procedure for testing the Scrubber system function to ensure it was maintained and operated to effectively address emergency conditions involving chlorine gas release from chlorine storage room equipment. Company MI procedures, documents named Chlorine Scrubber PM-Yearly, Chlorine Scrubber PM-Monthly and Chlorine Scrubber PM-Quarterly, did not establish procedures to test system function, such as but not limited to, periodic analysis of scrubbing fluid content for scrubbing capacity and periodic function testing of the entire system.   b. On or about March 18, 2025, the employer's mechanical integrity (MI) procedures for the Scrubber system lacked specificity regarding inspection of the pumps. Company MI procedures, documents named Chlorine Scrubber PM-Monthly and Chlorine Scrubber PM-Quarterly, lacked specificity regarding inspection of the pumps for pump strainer cleaning, use of the HMI for pump removal from service, use of the HMI for pump return to service, amperage measurements, and pump line pressure measurements. The PM procedures did not include instructions regarding performance of strainer cleaning or provide any specific instructions for HMI use in item 3. In addition, the quarterly PM procedure did not address instructions for amperage measurements, pass/fail criteria for pumps, where to record amperage data, and how to take and record pump pipe line pressure required in item 7.  c. On or about March 18, 2025, the employer's mechanical integrity (MI) procedure for the Scrubber system lacked specificity for instrumentation calibration.  Company MI procedures, the document named Chlorine Scrubber PM-Quarterly, lacked specificity for inspection and testing of instrumentation regarding the pH sensor calibration in item 8. The procedure did not provide any instruction on how to perform calibration, equipment necessary for sensor calibration, pass/fail criteria, and instruction regarding where to record sensor calibration data.  d. On or about March 18, 2025, the employer's mechanical integrity (MI) procedure, the document named Chlorine Scrubber PM-Monthly, lacked specificity regarding inspection of the blower motors in item 6. The procedure did not include any pass/fail criteria for amperage and instruction regarding where to record amperage data.  e. On or about March 18, 2025, the employer's mechanical integrity (MI) procedure for the Scrubber system did not establish procedures for internal pump inspection and testing. Company MI procedures, the document named Chlorine Scrubber PM-Yearly, did not include instructions to perform any internal inspection or testing of the pumps. The procedure did not address impeller inspection for casing clearance or impeller balance, bearings or lubrication for bearings, pump seals, pump motor shaft inspection and tests for the performance metrics related to flow rate and temperature readings for comparison with baseline values.  f. On or about March 18, 2025, the employer's mechanical integrity (MI) procedure for the Scrubber system did not establish procedures for functional testing of the blower/blower motor. Company MI procedures, documents named Chlorine Scrubber PM-Yearly, Chlorine Scrubber PM-Monthly and Chlorine Scrubber PM-Quarterly, did not address blower/blower motor performance inspection and tests related to Scrubber system's blower motors used for air movement of the chlorine gas stream(s) into the Scrubber system. The procedures did not include instructions to perform any air flow measurements, design parameters for blower/blower motor performance, system design air flow parameters and instruction for use of measurements for comparison to design operational and emergency condition performance of the Scrubber system.  g. On or about March 18, 2025, the employer's mechanical integrity (MI) procedure for the chlorine system did not establish procedures for internal inspection of the venturi system equipment. Company MI procedures, the document named Chlorine Processing Equipment PM-Yearly, did not address internal inspection procedures for the venturi eductor, the De Nora Fixed Orifice Ejector, and associated components used for chlorination of the aqueous stream in the covered process. The procedures did not include inspection procedures to address effects of corrosion from the chlorine service and other potential damage mechanisms on the venturi eductor components to maintain the integrity of components, such as, but not limited to, flanges, flanged pipe, the ejector body, gaskets, nozzle, ejector throat, check valve bodies, diaphragms, o-rings, unions and springs.  h. On or about March 18, 2025, the employer's mechanical integrity (MI) procedure for the chlorine system lacked specificity regarding inspection of the ton chlorine containers and safety system components. Company MI procedures, documents named Chlorine Processing Equipment PM-Yearly and Chlorine Processing Equipment PM Quarterly, lacked specificity in the inspection procedures for chlorine containers and auto-closure devices in line item 8 (for both PMs.) The procedures did not include clear instruction for steps to use the HMI (i.e., how to use it) to isolate ton containers using the air solenoid valve in step 3, and did not include specific instructions, such as specialty tool use for tightening valves or pass/fail criteria for tightness checks in step 6. The procedures did not include clear instructions on checking and/or adding oil to auto-closure devices in step 7, such as specific material for use and criteria (i.e., type oil and volume oil necessary in device). The procedures that required verification of the "proper operation" of each auto-closure device in step 7 lacked information on pass/fail criteria for the auto-closure device functional test and did not include specific instructions for how to perform the test. Additionally, step 9 did not include clear instructions for the steps necessary to switch the process room to allow for continuation of the procedures in the second chlorine storage room as required in step 10.  i. On or about March 18, 2025, the employer's mechanical integrity (MI) procedures for the chlorine system and scrubbing system electrical testing did not address precautions to perform the required tasks safely. Company MI procedures did not include instructions for safely performing electrical checks in electrical panel boxes and electrical disconnect boxes, such as, but not limited to, taking amperage measurements on pumps and blower motors. The procedures did not address visual inspection of equipment prior to amperage testing, the use of specialty tools, or list any electrical protective equipment requirements, such as, but limited to, protective barriers, protective gloves, protective face protection, and/or body protection for protection against electrical contact and other electrical hazards. Such MI procedures included Chlorine Processing Equipment PM-Yearly and Chlorine Processing Equipment PM Quarterly line items 1 and for Chlorine Scrubber PM-Yearly and Chlorine Scrubber PM-Monthly line items 1, 6 and 7 and Chlorine Scrubber PM-Quarterly line item 1. Additionally, Chlorine Processing Equipment PM-Yearly and Chlorine Processing Equipment PM Quarterly line items 1 lack specificity for thermal camera use while working in live electrical panels and does not include pass/fail criteria for "hot spots."  j. On or about March 18, 2025, the employer's mechanical integrity (MI) procedures for Chlorine system instrumentation testing lacked specificity. Company MI procedures, the document named Chlorine Processing Equipment PM-Yearly, lacked specificity in the procedures for testing and calibrating instrumentation. The procedures failed to include specific instructions for temperature sensor testing of chlorinated water, did not include pass/fail criteria for temperature sensor testing and instructions for testing documentation in line item 9.  In a separate MI procedure titled Chlorine Processing Equipment PM-Yearly, the  procedures failed to include specific instructions for testing/calibrating chlorine gas pressure sensors, pass/fail criteria for pressure sensor testing and instructions for testing/calibration documentation (in line item 1 of the document version with 2 estimated craft hours and no production downtime estimated). In another separate MI procedure titled Chlorine Processing Equipment PM-Yearly, the procedure failed to include specific instructions for testing/calibrating chlorine gas monitoring sensors, pass/fail criteria for chlorine gas monitoring sensor testing and instructions for testing/calibration documentation (in line item 1 of the document version with 4 estimated craft hours and no production downtime estimated.) Additionally, the testing/calibrating procedures for chlorine gas monitoring sensors included an annual schedule for performing the testing/calibration when the manufacturer's calibration procedure recommends calibration performance once every 6 months.  k. On or about March 18, 2025, the employer's mechanical integrity (MI) procedures lacked inspection and testing for safety instrumented systems and operating systems. Company MI procedures for Chlorine Processing Equipment PMs and Chlorine Scrubber PMs did not establish procedures for functional testing of the safety instrumented systems that controlled safety systems involved with emergency stop controls in the chlorine storage rooms, auto-closure devices for ton chlorine containers in the chlorine storage rooms, and ventilation system damper controls for removing chlorine gas from chlorine storage rooms during emergency conditions. Company MI procedures for Chlorine Processing Equipment PMs and Chlorine Scrubber PMs did not establish procedures for inspection and testing of operating systems used to control process conditions during normal and emergency operations.

Issued

Sep 8, 2025

Abate by

Dec 10, 2025

Penalty

Initial $11,823 · Current $11,823

Hazardous substances 0640

General-duty citation text

29 CFR  1910.119(n): Emergency planning and response. The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan shall include procedures for handling small releases. Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120 (a), (p) and (q).  As of and prior to March 18, 2025, the employer failed to establish and implement an emergency action plan in accordance with 29 CFR 1910.38.  a. The employer's emergency action plan did not establish specific procedures for reporting a chlorine release from covered process equipment. SOP-EHS-211, Emergency Action Plans, revision 06, Section 8.0 Chemical Spill, lacked specificity in that the procedure did not address chlorine, chlorine piping or chlorine 1-ton containers, step 2 did not provide how employees report a chlorine release, and step 5 did not specify how to contact the Incident Command Team. SOP-EHS-201, Incident Management Standard, version 0, lacked specificity in that the procedure did not address chlorine, lacked specificity in employee responsibilities for reporting "incidents", and only required "incident" reporting before the end of the shift. The work instruction WI-EHS-201-01, Incident Response Checklist, version 0, lacked specificity in that the procedure does not address chlorine, lacked specificity in employee responsibilities for reporting "incidents", and lacked specificity for reporting in Section 6.3 Hazardous Material Spill Response, steps 6.3.1 through 6.3.5.  Note: 29 CFR 1910.38(c)(1) is required for PSM-covered processes by 29 CFR 1910.119(n) and can be used to abate this hazardous condition.   b. The employer's emergency action plan did not establish clear procedures for evacuation and employee accountability for chlorine releases from covered process equipment. SOP-EHS-211, Emergency Action Plans, revision 06, Section 8.0 Chemical Spill, lacked specificity in that the procedure did not address chlorine, did not address how an employee would notify employees, and contractors to immediately evacuate and how the plan would ensure all personnel had been notified to evacuate.SOP-EHS-211, Emergency Action Plans, revision 06, Section 8.0 Chemical Spill, step 3, lacked specificity regarding a chlorine release based evacuation for use of windsock observations and evacuation rallying point location for headcount, as well as how headcount would be performed to account for each person. The plan does not specify how the headcount for determination of employee accountability would occur for any emergency evacuation. SOP-EHS-201, Incident Management Standard, version 0, did not address evacuation procedures for chlorine release. The work instruction WI-EHS-201-01, Incident Response Checklist, version 0, lacked specificity regarding evacuation in that it did not address chlorine, lacked specificity in step 6.3.1 regarding determining risk level prior to evacuation, and lacked specificity in step 6.3.2 regarding determining if a condition was hazardous prior to evacuation.  Note: 29 CFR 1910.38(c)(2) and (c)(4) are both required for PSM-covered processes by 29 CFR 1910.119(n) and can be used to abate this hazardous condition.  c. The employer's emergency action plan did not include distinct signals for chemical releases.  Note: 29 CFR 1910.165 is required by 29 CFR 1910.38(d), which is required for PSM-covered processes by 29 CFR 1910.119(n), therefore 29 CFR 1910.38(d) can be used to abate this hazardous condition.  During a chlorine release that triggers an emergency evacuation, employees have increased risk for chlorine exposure and associated inhalation hazards.

Issued

Sep 8, 2025

Abate by

Oct 14, 2025

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.29(f)(2): Finger clearance.  The minimum clearance between handrails and any other object is 2.25 inches (5.7 cm);   a. On or about March 18, 2025, the employer failed to provide the minimum finger clearance required between the handrail on the stairway used to access the upper level of line 4.  The handrail was welded directly to the upper-level platform, which did not allow for finger clearance.