OSHA Inspection: PREGIS CORPORATION

Issued

2015-03-13 00:00:00

Abate by

2015-04-17 00:00:00

Penalty

Initial $5000.00 · Current $3000.00 Reduced

General-duty citation text

29 CFR 1910.22(a)(1): All places of employment, passageways, storerooms or service rooms were not kept clean and orderly or in a sanitary condition.    a) Building 2, production area, above Line 11 and adjacent area(s) - On or prior to September 18, 2014, structural members, pipes, conduits, raceways, ducts, lighting fixtures, mezzanines, and similar equipment/areas were not kept free from hazardous accumulations of explosive combustible dust.

Issued

2015-03-13 00:00:00

Penalty

Initial $5000.00 · Current $3000.00 Reduced

General-duty citation text

29 CFR 1910.37(a)(2): Exit routes were not arranged so that employees would not have to travel toward a high hazard area, unless the path of travel was effectively shielded from the high hazard area by suitable partitions or other physical barriers:    (a) Building 2 -- On or prior to 9/18/14, primary exit routes along north and west exterior of building were arranged such that path of travel approached Line 11 process equipment which utilized a hazardous quantity of isobutane.

Issued

2015-03-13 00:00:00

Abate by

2015-04-17 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting.  (a) Butane Bulk Storage and Foam Extrusion Process -- On or prior to September 18, 2014, the process hazard analysis did not address facility siting issues, including but not limited to:  proximity of safe emergency egress route(s) and location of emergency muster point(s) with respect to location of hazardous process equipment.

Issued

2015-03-13 00:00:00

Abate by

2015-04-17 00:00:00

Penalty

Initial $5000.00 · Current $3000.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): Information pertaining to the equipment in the process did not include piping and instrument diagrams (P&ID's):      (a) Butane bulk storage -- On or prior to September 18, 2014, Piping and Instrumentation Diagram C92-102 (revision date 9/6/12) and D98-189 (revision date 9/6/12) were not updated to reflect existing process equipment, including but not limited to:  Removal of a 2" Fisher N550-16 Emergency Shutoff Valve (ESV), nitrogen line, and adjacent 2" globe valve, which had been removed and replaced with a stainless steel flex line and a ball valve.      (b) Butane bulk storage -- On or prior to September 18, 2014, Piping and Instrumentation Diagram C92-102 (revision date 9/6/12) and D98-189 (revision date 9/6/12) were not updated to reflect existing process equipment, including but not limited to:  Installation of two (2) stainless steel flex (anti-vibration) lines at outlets to Corken LP pumps.    (c) Butane bulk storage -- On or prior to September 18, 2014, Piping and Instrumentation Diagram C92-102 (revision date 9/6/12) and D98-189 (revision date 9/6/12) were not updated to reflect existing process equipment, including but not limited to:  Installation of internal emergency shut-off valves on butane bulk storage tank.

Issued

2015-03-13 00:00:00

Abate by

2015-04-17 00:00:00

Penalty

Initial $5000.00 · Current $3000.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process.    Butane Bulk Storage and Foam Extrusion Process -- On and prior to September 18, 2014, the Process Hazard Analysis (PHA)did not address the following hazard(s):      (a) Hazards associated with Line 11 process equipment which could affect the safety of the process, including but not limited to:  waste gas emission control system, including ventilation system(s) and RTO unit.       (b) Hazards associated with production processes or equipment, including combustible dust and flammable vapor ignition hazards, which could affect the safety of the Line 11 extrusion process, including but not limited to: combustible dust hazards associated with the former PK production line and isobutane vapor ignition hazards associated with storage of foam product (off line aging) in the building.

Issued

2015-03-13 00:00:00

Abate by

2015-04-17 00:00:00

Penalty

Initial $7000.00 · Current $4000.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not assure that PHA recommendations were resolved in a timely manner.    Butane Bulk Storage and Foam Extrusion Process -- On or prior to September 18, 2014, the status of the following recommendations of the June 2012 PHA were not resolved:    (a) Node 1, #11 -- 11.6.1.1  "Add PSM mechanical integrity and annual operating procedures review to quarterly management review"; date to be completed by:  10/14/15    (b) Node 3, #20 -- 19.3.1.1 "Investigate installation of flow or pressure switch to shut down Corken of feed to LEWA pumps.  Stainless steel above and below ground."  Stainless tubing running into building." date to be completed by:  12/01/14    (c) Node 3, #29 --  29.2.1.1 "Investigate underground piping inspection criteria and standards"; date to be completed by:  12/01/14

Issued

2015-03-13 00:00:00

Abate by

2015-05-15 00:00:00

Penalty

Initial $7000.00 · Current $4000.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:    (a) Butane Bulk Storage and Foam Extrusion Process:  On or prior to September 18, 2014, inspection and testing procedures did not include provisions for inspection and testing of underground butane supply and vapor return lines.

Issued

2015-03-13 00:00:00

Abate by

2015-04-17 00:00:00

Penalty

Initial $5000.00 · Current $3000.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iv): The employer did not document each inspection and test that was performed on process equipment wherein the documentation identified the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.    (a) Butane Bulk Storage and Foam Extrusion Process -- On or prior to September 18, 2014, the employer did not document each inspection and test that was performed on pressure relief valves (PRVs) in the Receiving (truck stanchion), Butane Bulk Storage, Low Pressure Transport, and High Pressure Transport systems.

Issued

2015-03-13 00:00:00

Abate by

2015-04-17 00:00:00

Penalty

Initial $7000.00 · Current $4000.00 Reduced

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 on paragraph (d) of this section) in a safe and timely manner when necessary means were taken to assure safe operation:    (a) Butane Bulk Storage Tank -- On or prior to September 18, 2014, external transfer piping and components were not painted or otherwise suitably protected from corrosion.    (b) Butane Bulk Storage Tank -- On or prior to September 18, 2014, external fill pipe was supported by a temporary support (welding pipe stand).    (c) Butane Bulk Storage Tank -- On or prior to September 18, 2014, SS butane liquid and vapor return lines connecting the bulk storage tank to the building were not protected from physical damage by vehicles at the southwest corner of the building.

Issued

2015-03-13 00:00:00

Abate by

2015-04-17 00:00:00

Penalty

Initial $5000.00 · Current $3000.00 Reduced

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not implement procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process.    (a) On and prior to September 18, 2014, the employer did not implement procedures to manage the following identified process changes, including but not limited to:  Butane yard -- Continued use of leaking fill pipe; reported 11/27/13, not repaired until 5/16/14.    (b) On and prior to September 18, 2014, the employer did not implement procedures to manage the following identified process changes, including but not limited to:  Butane yard -- Repair and replacement of stuck globe valve; gate valve replaced with ball valve; 7/16/14    (c) On and prior to September 18, 2014, the employer did not implement procedures to manage the following identified process changes, including but not limited to:  Butane yard -- Removal of pipe union and emergency shutoff valve; assembly replaced with flex pipe and new union; 7/28/14    (d) On and prior to September 18, 2014, the employer did not implement procedures to manage the following identified process changes, including but not limited to:  PK line -- Construction, startup, operation, shutdown, and removal of the PK production line which created a hazardous quantity of combustible dust, 2010 through summer 2014.

Issued

2015-03-13 00:00:00

Abate by

2015-04-17 00:00:00

Penalty

Initial $5000.00 · Current $3000.00 Reduced

General-duty citation text

29 CFR 1910.119(l)(4): Process safety information required by paragraph (d) of this section was not updated when a change covered by this paragraph resulted in a change in the process safety information.      (a) Butane bulk storage -- On or prior to September 18, 2014, P&IDs C92-102 (revision date 9/6/12) and D98-189 (revision date 9/6/12) were not updated to reflect changes to existing process equipment, including but not limited to:   Removal of a 2" Fisher N550-16 Emergency Shutoff Valve (ESV), nitrogen line, and adjacent 2" globe valve, which had been removed and replaced with a stainless steel flex line and a ball valve.      (b) Butane bulk storage -- On or prior to September 18, 2014, P&IDs C92-102 (revision date 9/6/12) and D98-189 (revision date 9/6/12) were not updated to reflect changes to existing process equipment, including but not limited to: Installation of two (2) stainless steel flex (anti-vibration) lines at outlets to Corken LP pumps.    (c) Butane bulk storage -- On or prior to September 18, 2014, P&IDs C92-102 (revision date 9/6/12) and D98-189 (revision date 9/6/12) were not updated to reflect changes to existing process equipment, including but not limited to:  Installation of internal emergency shut-off valves on butane bulk storage tank.

Issued

2015-03-13 00:00:00

Abate by

2015-04-17 00:00:00

Penalty

Initial $7000.00 · Current $4000.00 Reduced

General-duty citation text

29 CFR 1910.119(m)(1): The employer did not investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace.    (a) On or prior to September 18, 2014, investigation reports were not available for the following incident(s), including but not limited to:  Line 11 Extruder BBL -- Leaking plastic creating a possible fire hazard; 9/21/14    (b) On or prior to September 18, 2014, investigation reports were not available for the following incident(s), including but not limited to:  Line 11 Extruder BBL -- Leaking plastic creating a possible fire hazard; 6/12/14    (c) On or prior to September 18, 2014, investigation reports were not available for the following incident(s), including but not limited to:    Butane yard -- Butane leak from leaking pipe union/shutoff valve; 7/28/14    (d) On or prior to September 18, 2014, investigation reports were not available for the following incident(s), including but not limited to:  Butane yard -- Butane leak from leaking pipe union; 11/27/13

Issued

2015-03-13 00:00:00

Penalty

Initial $5000.00 · Current $3000.00 Reduced

General-duty citation text

29 CFR 1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected:    (a) Butane Bulk Storage and Foam Extrusion Process -- On or prior to September 18, 2014, the employer did not promptly document or determine the resolution of recommendations from the February 24, 2012 PSM compliance audit.  PSM compliance audit recommendations which were still open on or prior September 18, 2014 included, but are not limited to:   Update Process Safety information, including P&IDs and safety systems information (closed 10/14/14).    (b) Butane Bulk Storage and Foam Extrusion Process -- On or prior to September 18, 2014, the employer did not promptly document or determine the resolution of recommendations from the February 24, 2012 PSM compliance audit.  PSM compliance audit recommendations which were still open on or prior September 18, 2014 included, but are not limited to:  Update historical PHA documentation to include all PHA revalidations and ensure closure of previous PHA recommendations (closed 10/14/14)     (c) Butane Bulk Storage and Foam Extrusion Process -- On or prior to September 18, 2014, the employer did not promptly document or determine the resolution of recommendations from the February 24, 2012 PSM compliance audit.  PSM compliance audit recommendations which were still open on or prior September 18, 2014 included, but are not limited to:  Ensure PSM awareness training and JSA training are complete (closed 10/30/14).    (d) Butane Bulk Storage and Foam Extrusion Process -- On or prior to September 18, 2014, the employer did not promptly document or determine the resolution of recommendations from the February 24, 2012 PSM compliance audit.  PSM compliance audit recommendations which were still open on or prior September 18, 2014 included, but are not limited to:  Locate historical documentation of contractor work on covered process, including installation of internal valves on the butane storage tank (closed 10/24/14).    (e) Butane Bulk Storage and Foam Extrusion Process -- On or prior to September 18, 2014, the employer did not promptly document or determine the resolution of recommendations from the February 24, 2012 PSM compliance audit.  PSM compliance audit recommendations which were still open on or prior September 18, 2014 included, but are not limited to:  Ensure Mechanical Integrity program, including MI inspections, are properly conducted and documented.   Verify documentation of relief valve inspection and testing (closed 10/24/14).    (f) Butane Bulk Storage and Foam Extrusion Process -- On or prior to September 18, 2014, the employer did not promptly document or determine the resolution of recommendations from the February 24, 2012 PSM compliance audit.  PSM compliance audit recommendations which were still open on or prior September 18, 2014 included, but are not limited to:  Locate MOC documentation for installation of internal valves on butane storage tank.  Confirm that no MOCs have been documented (closed 10/24/14)    (g) Butane Bulk Storage and Foam Extrusion Process -- On or prior to September 18, 2014, the employer did not promptly document or determine the resolution of recommendations from the February 24, 2012 PSM compliance audit.  PSM compliance audit recommendations which were still open on or prior September 18, 2014 included, but are not limited to:  Confirm that no PSM incidents have occurred and/or been documented (closed 10/24/14).    (h) Butane Bulk Storage and Foam Extrusion Process -- On or prior to September 18, 2014, the employer did not promptly document or determine the resolution of recommendations from the February 24, 2012 PSM compliance audit.  PSM compliance audit recommendations which were still open on or prior September 18, 2014 included, but are not limited to:  Compile PSM documents into a common location/binder (closed 10/24/14).

Issued

2015-03-13 00:00:00

Abate by

2015-06-26 00:00:00

Penalty

Initial $5000.00 · Current $3000.00 Reduced

General-duty citation text

29 CFR 1910.132(d)(1): The employer did not assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE):    (a) Building 2, during maintenance work  -- On or prior to 9/18/14, the employer did not conduct an arc flash hazard assessment to determine personal protective equipment needed to protect employees from exposure to arc flash hazards.

Issued

2015-03-13 00:00:00

Abate by

2015-06-26 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.335(a)(1)(i): Employees working in areas where there were potential electrical hazards were not provided with electrical protective equipment that was appropriate for the specific parts of the body that needed to be protected and for the work being performed:    (a) Building 2, during maintenance activities -- On or prior to 9/18/14, the employer did not provide employees with  personal protective equipment needed for protection from exposure to arc flash hazards during maintenance procedures, including procedures for de-energizing equipment and testing to verify absence of hazardous voltage.

Issued

2015-03-13 00:00:00

Abate by

2015-06-26 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.335(b)(1): Safety signs, safety symbols, or accident prevention tags were not used where necessary to warn employees about electrical hazards which may endanger them as required by 29 CFR 1910.145.     (a) Building 2, electrical system and components  -- On or prior to 9/18/14, the employer did not install arc flash hazard warning labels to inform employees of flash protection boundaries and personal protective equipment needed for protection from exposure to arc flash hazards.