OSHA Inspection: DOW CHEMICAL, TEXAS INC.

Issued

2013-01-11 00:00:00

Abate by

2013-04-01 00:00:00

Penalty

Initial $7000.00 · Current $7000.00

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(B): The employer did not implement precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment:    This violation is most recently observed in the N-5 Ammonia Recycle Unit at Dow Chemical, when the employer did not develop and implement engineering controls including but not limited to, torqueing specification and safety precautions including proper PPE in the Cartridge Filter Change procedure to ensure a safe operation.

Issued

2013-01-11 00:00:00

Abate by

2013-04-01 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(f)(3): The operating procedure was not reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities.     This violation was most recently observed in the N5-Ammonia Recycling Unit of the Dow Chemical in Deer Park, Texas when the Recycle Cartridge Filter Change critical procedure was not reviewed and updated to reflect current operating practices; including operators did not use the IR thermometer gun to verify the housing temperature and did not observe through the sight-glass window to verify isolation valves fully blocked.

Issued

2013-01-11 00:00:00

Abate by

2013-04-01 00:00:00

Penalty

Initial $4000.00 · Current $1000.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment was not consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience:    a)   This violation is most recently observed in the N-5 Ammonia Recycle Unit at Dow Chemical, when the employer did not implement Owner's visual external inspection every 2.5 year per section 2.10.3 of the GMISS (Global Mechanical Integrity Safety Standard) policy and procedure to maintain the Cartridge Filter.      b)   This violation is most recently observed in the N-5 Ammonia Recycle Unit at Dow Chemical, when the inspection and test frequency on the sight-glass of Cartridge Filter did not follow the employer GMISS (Global Mechanical Integrity Safety Standard) section 2.10.8 or GMIM (Global Mechanical Integrity Manual) 5.5.7.2 policy and procedure.

Issued

2013-01-11 00:00:00

Abate by

2013-04-01 00:00:00

Penalty

Initial $7000.00 · Current $7000.00

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation:    a)   This violation was last observed in the N-5 Ammonia Recycle Unit at Down Chemical, Deer Park; when the employer operated the Cartridge Filter with the landing surfaces where the eyebolts from the filter body land on the head are worn.  Bolts have tendency to slip off during the securing of the filter head.    b)   This violation is most recently observed in the N-5 Ammonia Recycle Unit at Dow Chemical, when the employer did not ensure the sight-glass window on the Cartridge Filter was visible for observation of the internal fluids color.

Issued

2013-01-11 00:00:00

Abate by

2013-04-01 00:00:00

Penalty

Initial $7000.00 · Current $7000.00

General-duty citation text

29 CFR 1910.119(d)(3)(i)(A):  Employer did not have complete information pertaining to the equipment in the process; including material of construction:                                                             -In the Alternative-    29 CFR 1910.119(d): Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer did not complete a compilation of written process safety information before conducting any process hazard analysis required by the standard.        This violation was most recently observed in the Ammonia Recycle Unit when the employer failed to document and maintain accurate process safety information (PSI) for the Cartridge Filter, such as but not limited to materials of construction, accurate engineering drawings, operation and maintenance requirements.

Issued

2013-01-11 00:00:00

Abate by

2013-04-01 00:00:00

Penalty

Initial $7000.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not 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:    This violation was most recently observed in the Ammonia Recycle Unit when the employer did not follow its Management of Change policy and operated the Cartridge Filter without effectively managing and documenting the equipment change which included the modifications of the bolting system on the Cartridge Filter head.

Issued

2013-01-11 00:00:00

Abate by

2013-04-01 00:00:00

Penalty

Initial $1000.00 · Current $1000.00

General-duty citation text

29 CFR 1910.119(c)(1): Employer did not develop a written plan of action regarding the implementation of the employee participation required by this paragraph:    This violation was most recently observed at Dow Chemical in Deer Park, Texas when the employer did not implement the employee participation program including but not limited to, the involvement of employee representatives during the investigation of an incident which occurred on July 16, 2012 in the N5-Ammonia Recycling Unit.