Home > Industrial, Legal, Lockout Tagout > NY: OSHA Fines Hunter Panels LLC $123K – Lockout Tagout and Electrical

NY: OSHA Fines Hunter Panels LLC $123K – Lockout Tagout and Electrical

Kingston, NY: OSHA has cited a manufacturer of roof insulation panels with 23 alleged serious safety violations following an inspection that began in July 2012.  OSHA found several deficiencies in the plant’s process safety management (PSM) program.  The chemical was n-pentane, an organic compound used in the manufacturing process. The cited deficiencies included missing PSI, failing to develop and implement SWP, correct equipment deficiencies, follow up on the findings of compliance audits, address all hazards identified during a PHA, and document the resolution of corrective actions, in the plant’s emergency response, confined space and hazardous energy control programs, lack of personal protective equipment, accumulation of combustible dust, as well as fall and respirator hazards.  Here is a breakdown of the citations…

Combustible Dust

  • 1910.22(a)(1) – Combustible Dusts on structures and surfaces (Serious; $5K)

Process Safety Information

  • 1910.119(d)(1)(v) – no corrosivity data on the metallic Type 321 SS hoses used in the process (Serious; $7K)

Process Hazard Analysis

  • 1910.119(e)(3)(i) – The PHA did not address the hazards of a combustible dust deflagration, a release of pentane due to the failure of the SS braided hoses, the CUNO filter plugging at the pentane pump. (Serious; $7K)
  • 1910.119(e)(5) – No system to track 2007 and 2012 PHA recommendations to closure, items were not closed in a timely manner, the resolutions were not documented, and did not communicate the actions to operating, maintenance and other employees who work assignments were in the process. (Serious; $5K)

Operating Procedures

  • 1910.119(f)(4) – No line break procedure and no LOTO and CS Entry procedures to address the isolation of pentane lines during maintenance of a laminator. (Serious; $7K)

Mechanical Integrity

  • 1910.119(j)(2) – No maintenance procedures to maintain the on-going integrity of pentane piping systems, including corrosion under insulation (CUI) inspection procedures. (Serious; $7K)
  • 1910.119(j)(4) – the frequency of inspections and tests of the Type 321 SS Flexible Metallic hose was not determined.  (Serious; $0)
  • 1910.119(j)(5) – did not correct deficiencies in the steel piping to and from the CUNO pentane filter was not painted in accordance with design specification, NFPA-30, or other methods to provide similar protection from corrosion.  (Serious; $7K)

Management of Change

  • 1910.119(l)(1) – Hazards were not evaluated through an MOC for the addition of the CUNO Auto-Klean Model EG Filter at the pentane transfer pump.  (Serious; $7K)

Compliance Audit

  • 1910.119(o(4) – did not document closures from the 2007 and 2009 audits.(Serious; $7K)

Emergency Response

  • 1910.120(q)2)(iii) – the emergency response plan did not define the types of releases and emergencies that could potentially require an emergency response vs. incidental releases.  (Serious; $5K)
  • 1910.120(q)2)(iv) – the emergency response plan identified only one location as an assembly area; alternative areas were not considered.  (Serious; $0)
  • 1910.120(q)(8)(i) – The safety manager, acting as the emergency coordinator, did not have annual refresher training. (Serious; $5K)

Personal Protective Equipment

  • 1910.133(a)(1) – personnel were not wearing goggles to protect against dripping grease and dust while lubricating the Laminator. (Serious; $3K)
  • 1910.134(c)(1) – No written respiratory protection program for required respirator use.  Employees were required to use 3M 8210 disposable N95 respirators for certain jobs.  (Serious; $5K)
  • 1910.134(e)(1) – No medical evaluations to determine employee’s ability to use a respirator. (Serious; $0)
  • 1910.134(k)(3) – No respirator training. (Serious; $0)
  • 1910.138(b) – Wearing improper gloves while opening chemical pumps to remove and clean out filters. (Serious; $6K)
  • 1910.134(d)(1)(iii) – employer did not identify and evaluate the respiratory hazards in the workplace, including a reasonable estimate of employee exposures to respiratory hazards and identification of the contaminants chemical state and physical form. (Other-than-Serious; $0)

Permit-Required Confined Spaces

  • 1910.146(d)(3)(i) – did not develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including specifying acceptable entry conditions, such as: the speed of the conveyor, the temperature in the laminator, and the level of pentane.  (Serious; $5K)
  • 1910.146(d)(5)(i) – did not test conditions in the permit spa e to determine if acceptable entry condition existed before entry was authorized. (Serious; $0)
  • 1910.146(f)(9) – entry permit did not identify the acceptable entry conditions. (Serious; $0)
  • 1910.146(d)(9) – no procedures for summoning rescue and emergency services to rescue employees and for preventing unauthorized personnel from attempting a rescue. (Serious; $5K)
  • 1910.146(j)(4) – entry supervisors did not verify that entry supervisor(s) verified that rescue services were available and that the means for summoning them were operable.  (Serious; $0)
  • 1910.146(k)(1)(i) – did not evaluate a prospective rescuer’s ability to respond a rescue summons in a timely manner, considering the hazard(s) identified.  The facility stated they would use “911”. (Serious; $0)
  • 1910.146(k)(1)(ii) – did not evaluate a prospective rescuer’s ability in terms of proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants.  The facility stated they would use “911”. (Serious; $0)
  • 1910.146(d)(3)(iii) – did not develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including isolating the permit space.  (Serious; $5K)
  • 1910.146(f)(7) – entry permit did not identify the hazards of the permit space to be entered.  (Serious; $0)
  • 1910.146(g)(1) – entry supervisor that supervising an entry did not receive adequate training about the control of hazards due to the employer having an inadequate procedure for entry.  (Serious; $5K)
  • 1910.146(f)(3) – an entry permit had the incorrect date of entry (Other-than-Serious; $0)

LOTO (Lockout Tagout)

  • 1910.147(c)(4)(i) – no machine specific LOTO procedures for entry into the laminator and no procedures for line breaks. (Serious; $5K)
  • 1910.147(c)(7)(i)(A) – authorized personnel did not receive training in the recognition of applicable hazardous energy sources, the type and magnitude of energy available in the workplace and the methods and means necessary for energy isolation and control.  (Serious; $5K)

Electrical

  • 1910.303(b)(2) – a two-receptacle 120V metallic outlet box was used on the end of a flexible cord to provide electricity to a fluorescent lamp during a PRCS entry.  The box was designed to be wall mounted instead of being placed on the floor. (Serious; $3K)
  • 1910/305(g)(2)(iii) – a flexible cord attached to a fluorescent light was not provided with strain relief in that the outer shielding had separated from the light.  (Serious; $3K)

Story via safteng.net

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