From: "Stuart, Ralph" <Ralph.Stuart**At_Symbol_Here**KEENE.EDU>
Subject: [DCHAS-L] Crosby Arkema plant had 10 violations OSHA considered serious in 2012
Date: Tue, 5 Sep 2017 15:07:26 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 46EE5FF9-0E51-42D7-B819-BB2B5311F03F**At_Symbol_Here**

HOUSTON -- Fire burned at the Arkema plant in Friday night, the second issue there in 24 hours.

KHOU 11 looked into past issues at the plant.  In the latest OSHA report, which was from August of last year. OSHA had 10 violations, all of which were considered by OSHA as being serious.  Nine of those 10 dealt with safety management of highly-hazardous chemicals.

Those violations include:
- Not ensuring equipment was safe for hazardous location
- Having safety and inspection procedures that didn't follow good engineering practices
- Not inspecting and testing 11 pieces of equipment, including pipelines
- Not having records showing employees had proper training on operational procedures
- Not implementing written procedures for maintaining ongoing integrity of equipment
OSHA says all of the problems were fixed and the company paid $91,714 in fines.

The company says the fire was because of Harvey.  What's not clear if any of the PAST violations played a part.

OSHA press release from 2012

US Labor Department's OSHA cites Pennsylvania-based Arkema for safety violations at Houston facility

HOUSTON - The U.S. Department of Labor's Occupational Safety and Health Administration has cited King of Prussia, Pa.-based Arkema Inc. with 12 serious, one repeat and one other-than-serious violations for exposing workers to multiple safety hazards while producing organic chemicals at the company's Houston facility. OSHA's Houston North Area Office initiated an inspection of the Haden Road plant in January after receiving an employee complaint, and later expanded the inspection under the agency's process safety management national emphasis program for preventing or minimizing the catastrophic release of toxic, reactive, flammable or explosive chemicals. Proposed penalties total $117,100.

The serious violations include failing to compile process safety information on instruments used as safeguards and on relief system design, ensure that recognized and good engineering practices are used, follow recommended process hazard analysis procedures, and inspect and test equipment identified as safeguards. A serious violation occurs when there is substantial probability that death or serious physical harm could result from a hazard about which the employer knew or should have known.

The repeat violation is for failing to review and certify operating procedures on an annual basis to ensure that current practices are being followed. A repeat violation exists when an employer previously has been cited for the same or a similar violation of a standard, regulation, rule or order at any other facility in federal enforcement states within the last five years. A similar violation was cited in 2010.

The other-than-serious violation is for failing to develop safe work practices to control entrance into covered processes. An other-than-serious violation is one that has a direct relationship to job safety and health, but probably would not cause death or serious physical harm.

"Process safety management prevents the unexpected release of toxic, reactive or flammable liquids and gases in processes involving highly hazardous chemicals," said David Doucet, director of OSHA's Houston North Area Office. "It's vital that Arkema ensure that safeguards are in place to protect the safety of workers at this facility."

The citations can be viewed at*.

Arkema employs about 2,400 workers who produce industrial chemicals at 32 facilities in the United States and Canada, Mexico and Brazil. The company has 15 business days from receipt of its citations to comply, request an informal conference with OSHA's Houston North area director, or contest the citations and penalties before the independent Occupational Safety and Health Review Commission.

OSHA's standards contain specific requirements for the management of hazards associated with processes using dangerous chemicals. Additional information is available online at

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859


Previous post   |  Top of Page   |   Next post

The content of this page reflects the personal opinion(s) of the author(s) only, not the American Chemical Society, ILPI, Safety Emporium, or any other party. Use of any information on this page is at the reader's own risk. Unauthorized reproduction of these materials is prohibited. Send questions/comments about the archive to
The maintenance and hosting of the DCHAS-L archive is provided through the generous support of Safety Emporium.