Violation Detail
Standard Cited: 19100119 F01 III A Process safety management of highly hazardous chemicals.
Inspection Nr: 1524024.015
Citation: 01018
Citation Type: Serious
Abatement Date: 11/12/2021
Initial Penalty: $13,653.00
Current Penalty: $13,653.00
Issuance Date: 10/06/2021
Nr Instances: 7
Nr Exposed: 68
Related Event Code (REC): A;R
Gravity: 10
Report ID: 0522500
Contest Date: 10/25/2021
Final Order:
Emphasis:
Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
---|---|---|---|---|---|---|
Penalty | C: Contested | 10/29/2021 | $13,653.00 | 11/12/2021 | Serious | |
Penalty | Z: Issued | 10/06/2021 | $13,653.00 | 11/12/2021 | Serious |
Text For Citation: 01 Item/Group: 018 Hazard:
29 CFR 1910.119(f)(1): Operating procedures. The employer did not 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; a. On or about and prior to April 8, 2021, the written operating procedure, K3, K4, K5 Agitator Operation, RES-PRO-KO-007, failed to address the safety and health considerations for the hazards presented by the chemicals used in the process, such as xylene and VM&P (Naptha), with temperatures above solvent boiling point(s) during normal operating conditions which increase the risk for rapid pressurization and loss of containment exposing employees to the hazards of fire, explosion and struck-by hazards. b. On or about and prior to April 8, 2021, the written operating procedure, Scale Tanks General Operation and Pumping, RES-PRO-KO-017, failed to address the safety and health considerations for the hazards presented by the chemicals used in the process, such as xylene and VM&P (Naptha), with temperatures above solvent boiling point(s) during normal operating conditions which increase the risk for rapid pressurization and loss of containment exposing employees to the hazards of fire, explosion and struck-by hazards. c. On or about and prior to April 8, 2021, the written operating procedure, Kettle 3 Overhead Processing Procedure, RES-PRO-KO-022, failed to address the safety and health considerations for the hazards presented by the chemicals used in the process, such as xylene and VM&P (Naptha), with temperatures above solvent boiling point(s) during normal operating conditions which increase the risk for rapid pressurization and loss of containment exposing employees to the hazards of fire, explosion and struck-by hazards. d. On or about and prior to April 8, 2021, the written operating procedure, Kettle 3 Overhead Processing Procedure, RES-PRO-KO-022, failed to address the safety and health considerations for the hazards presented by the "acids" used in the process, such as but not limited to benzoic acid; such as the increased risk for "frothing" or "foaming" during normal operating conditions which increases the risk for resin material related blockage of flow in covered process equipment, rapid pressurization and loss of containment exposing employees to the hazards of fire, explosion and struck-by hazards. e. On or about and prior to April 8, 2021, the written operating procedure, Solvent Manifold Operation, RES-PRO-PLT-031, failed to address the safety and health considerations for the hazards presented by the "acids" used in the process, such as but not limited to benzoic acid; such as the increased risk for "frothing" or "foaming" during normal operating conditions which increases the risk for resin material related blockage of flow in covered process equipment, rapid pressurization and loss of containment exposing employees to the hazards of fire, explosion and struck-by hazards. f. On or about and prior to April 8, 2021, the written operating procedure, Solvent Manifold Operation, RES-PRO-PLT-031, failed to address the safety and health considerations for the hazards presented by the chemicals used in the process, such as xylene and VM&P (Naptha), with temperatures above solvent boiling point(s) during normal operating conditions which increase the risk for rapid pressurization and loss of containment exposing employees to the hazards of fire, explosion and struck-by hazards. g. On or about and prior to April 8, 2021, the written operating procedure, OPC Emergency Shutdown Procedure, RES-PRO-PLT-009, failed to address the safety and health considerations for the hazards presented by the chemicals used in the process, such as xylene and VM&P (Naptha), with temperatures above solvent boiling point(s) during normal operating conditions which increase the risk for rapid pressurization and loss of containment exposing employees to the hazards of fire, explosion and struck-by hazards. The procedure failed to specifically address catastrophic hazards, such as an uncontrolled vapor cloud release, that would trigger emergency evacuation.