US. Department of Labor Occupational Safety and Health Administration 919 Market Street Suite 900 Wilmington, DE 19801 Citation and Noti?cation of Penalty To: Inspection Number: 1361878 Croda Inc Inspection Date(s): 11/26/2018 - 05/23/2019 315 Cherry Lane Issuance Date: 05/24/2019 New Castle, DE 19720 Inspection Site: The violation(s) described in this Citation and 315 Cherry Lane .Noti?cation of Penalty is (are) alleged to have New Castle, DE 19720 occurred on or about the day(s) the inspection was made unless otherwise indicated within the description given below. This Citation and Noti?cation of Penalty (this Citation) describes violations of the Occupational Safety and Health Act of 1970. The penalty(ies) listed herein is (are) based on these violations. You must abate the violations referred to in this Citation by the dates listed and pay the penalties proposed, unless within 15 working days (excluding weekends and Federal holidays) from your receipt of this Citation and Noti?cation of Penalty you either call to schedule an informal conference (see paragraph below) or you mail a notice of contest to the US. Department of Labor Area Of?ce at the address shown above. Please refer to the enclosed booklet (OSHA 3000) which outlines your rights and reSponsibilities and which should be read in conjunction with this form. Issuance of this Citation does not constitute a ?nding that a violation of the Act has occurred unless there is a failure to contest as provided for in the Act or, if contested, unless this Citation is af?rmed by the Review Cormnission or a court. Posting - The law requires that a copy of this Citation and Noti?cation of Penalty be posted immediately in a prominent place at or near the location of the violation(s) cited herein, or, if it is not practicable because of the nature of the employer?s operations, where it will be readily observable by all affected employees. This Citation must remain posted until the violation(s) cited herein has (have) been abated, or for 3 working days (excluding weekends and Federal holidays), whichever is longer. Citation and Noti?cation of Penalty Page 1 of 38 OSHA-2 Informal Conference - An informal conference is not required. However, if you wish to have such a conference you may request one with the Area Director during the 15 working day contest period by calling 302- 573-6518. During such an informal conference you may present any evidence or views which you believe would support an adjustment to the citation(s) and/or penalty(ies). If you are considering a request for an informal conference to discuss any issues related to this Citation and Noti?cation of Penalty, you must take care to schedule it early enough to allow time to contest after the informal conference, should you decide to do so. Please keep in mind that a written letter of intent to contest must be submitted to the Area Director within 15 working days of your receipt of this Citation. The running of this contest period is not interrupted by an informal conference. If you decide to request an informal conference, please complete, remove and post the Notice to Employees next to this Citation and Noti?cation of Penalty as soon as the time, date, and place of the informal conference have been determined. Be sure to bring to the conference any and all supporting documentation of existing conditions as well as any abatement steps taken thus far. If conditions warrant, we can enter into an informal settlement agreement which amicably resolves this matter without litigation or contest. Right to Contest You have the right to contest this Citation and Notification of Penalty. You may contest all citation items or only individual items. You may also contest proposed penalties andfor abatement dates without contesting the underlying violations. Unless you inform the Area Director in writing that you intend to contest the citationts) and/or proposed penalty?es) within 15 working days after receipt. the citation(s) and the proposed penaltv?es) will become a ?nal order of the Occupational Safety and Health Review Commission and may not be reviewed by any court or agency. Penalty Payment Penalties are due within 15 working days of receipt of this noti?cation unless contested. (See the enclosed booklet and the additional information provided related to the Debt Collection Act of 1982.) Make your check or money order payable to Please indicate the hispection Number on the remittance. You can also make your payment electronically on gov. On the left side of the pay.gov homepage, you will see an option to Search Public Forms. Type and click Go. From the results, click on OSHA Penalty Payment Form. The direct link is: agencyFonnld:530903 34. You will be required to enter your inspection number when making the payment. Payments can be made by credit card or Automated Clearing House (ACH) using your banking information. Payments of $25,000 or more require a Transaction ID, and also must be paid using ACH. If you require a Transaction ID, please contact the OSHA Debt Collection Team at (202) 693-2170. OSHA does not agree to any restrictions or conditions or endorsements put on any check, money order, or electronic payment for less than the full amount due, and will process the payments as if these restrictions or conditions do not exist. Citation and Noti?cation of Penalty Page 2 of 38 OSHA-2 Noti?cation of Corrective Action For each violation which you do not contest, you must provide abatement certi?cation to the Area Director of the OSHA of?ce issuing the citation and identi?ed above. This abatement certi?cation is to be provided by letter within 10 calendar days after each abatement date. Abatement certi?cation includes the date and method of abatement. If the citation indicates that the violation was corrected during the inspection, no abatement certi?cation is required for that item. The abatement certi?cation letter must be posted at the location where the violation appeared and the corrective action took place or employees must otherwise be e?ectively informed about abatement activities. A sample abatement certi?cation letter is enclosed with this Citation. In addition, where the citation indicates that abatement documentation is necessary, evidence of the purchase or repair of equipment, photographs or video, receipts, training records, etc., verifying that abatement has occurred is required to be provided to the Area Director. Employer Discrimination Unlawful The law prohibits discrimination by an employer against an employee for ?ling a complaint or for exercising any rights under this Act. An employee who believes that he/she has been discriminated against may ?le a complaint no later than 30 days after the discrimination occurred with the U.S. Department of Labor Area Of?ce at the address shown above. Employer Rights and Responsibilities The enclosed booklet (OSHA 3000) outlines additional employer rights and responsibilities and should be read in conjunction with this noti?cation. Notice to Employees The law gives an employee or his/her representative the opportunity to object to any abatement date set for a violation if he/she believes the date to be unreasonable. The contest must be mailed to the U.S. Department of Labor Area Of?ce at the address shown above and postmarked within 15 working days (excluding weekends and Federal holidays) of the receipt by the employer of this Citation and Noti?cation of Penalty. Inspection Activity Data You should be aware that OSHA publishes information on its inspection and citation activity on the Internet under the provisions of the Electronic Freedom of Information Act. The information related to these alleged violations will be posted when our system indicates that you have received this citation. You are encouraged to review the information concerning your establishment at If you have any dispute with the accuracy of the information displayed, please contact this of?ce. Citation and Noti?cation of Penalty Page 3 of 38 OSHA-2 US. Department of Labor Occupational Safety and Health Administration NOTICE TO EMPLOYEES OF INFORMAL CONFERENCE An informal conference has been scheduled with OSHA to discuss the citation(s) issued on 05/24/2019. The conference will be held by telephone or at the OSHA of?ce located at 919 Market Street, Suite 900, Wilmington, DE 19801 on at . Employees and/or representatives of employees have a right to attend an informal conference. Citation and Noti?cation of Penalty Page 4 of 38 OSHA-2 CERTIFICATION OF CORRECTIVE ACTION WORKSHEET Inspection Number: 1361878 Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Issuance Date: 05/24/2019 List the speci?c method of correction for each item on this citation in this package that does not read ?Corrected During Inspection? and return to: US. Department of Labor Occupational Safety and Health Administration, 919 Market Street, Suite 900, Wilmington, DE 19801 Citation Number and Item Number was corrected on By (Method of Abatement): Citation Number and Item Number was corrected on By (Method of Abatement): Citation Number and Item Number was corrected on By (Method of Abatement): Citation Number and Item Number was corrected on By (Method of Abatement): Citation Number and Item Number was corrected on By (Method of Abatement): Citation Number and Item Number was corrected on By (Method of Abatement): I certify that the information contained in this document is accurate and that the affected employees and their representatives have been informed of the abatement. Signature Date Typed or Printed Name Title NOTE: 29 USC 666(3) whoever knowingly makes any false statements, representation or certi?cation in any application, record, plan or other documents ?led or required to be maintained pursuant to the Act shall, upon conviction, be punished by a ?ne of not more than $10,000 or by imprisonment of not more than 6 months or both. POSTING: A copy of completed Corrective Action Worksheet should be posted for employee review Citation and Noti?cation of Penalty Page 5 of 38 OSHA-2 U.S. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Inspection Date(s): 11/26/2018 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Family Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Citationl Iteml Type ofViolation: Serious 29 CFR The employer did not consult with employees and their representatives on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in this standard: a) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to consult with operators and their representatives on the development of all hazard studies conducted as part of the pre-startup safety review, contributing to employee exposure to the toxic, ?re, and explosion hazards posed by ethylene oxide. Pursuant to 29 CFR 1903.19, the employer must submit abatement certi?cation and documentation, required within 10 days after abatement date. The certi?cation shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records. ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM Date By Which Violation Must be Abated: 06/20/2019 Proposed Penalty: $11934.00 See pages 1 through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page 6 of 38 OSHA-2 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Inspection Date(s): 11/26/2018 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness. Citation 1 Item 2 a Type of Violation: Serious 29 CFR 1910.1 The employer did not compile written process safety information including piping and instrument diagrams a) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to update (?nalize) the before developing its ?nal process hazard analysis and before conducting the pre?startup safety review of the E0 plant. Incorrect or outdated do not allow the employer and the employees involved in operating the process to identify and understand the hazards posed by the E0 process exposing employees to the hazards of toxic and ?re/explosion hazards. Pursuant to 29 CFR 1903.19, the employer must submit abatement certi?cation and documentation, required within 10 days after abatement date. The certi?cation shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records. ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM Date By Which Violation Must be Abated: 06/20/2019 Proposed Penalty: 811934.00 See pages I through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page 7? of 38 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Inspection Date(s): 11/26/2018 - 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Citation I Item 2 Type of Violation: Serious 29 CF The employer did not perform a complete initial process hazard analysis (hazard evaluation) on processes covered by this standard. a) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to perform an adequate initial PHA that was based on detailed design when its 2015/2016 PHA prior to startup was based on information that pre-dated the Revision 0, set of that were issued for construction. Incorrect or outdated Issued for Construction version) do not allow the employer and the employees involved in conducting PHAS or operating the process to identify and understand the hazards posed by the E0 process exposing employees to the hazards of toxic and ?re/explosion hazards. Pursuant to 29 CFR 1903.19, the employer must submit abatement certi?cation and documentation, required within 10 days after abatement date. The certi?cation shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records. ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM Date By Which Violation Must be Abated: 06/20/2019 See pages 1 through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page 8 of 38 OSHA-2 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Inspection Date(s): 11/26/2018 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Citation] Item3 Type ofViolation: Serious 29 CFR The employer did not compile written process safety information including design codes and standards employed: a) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to develop and compile process safety information related to the design codes and standards used for the design and construction of equipment used at the new E0 plant such as but not limited to the following: ASME B1634, API 620, API 618, 674, NFPA 14, NFPA 15, NFPA 20, NFPA 22, NFPA 24, NFPA 72, NFPA 101, NFPA 496, NFPA 2113, ISA 84.00.01, etc., contributing to employee exposure to the toxic, ?re, and explosion hazards posed by ethylene oxide. Pursuant to 29 CF 1903.19, the employer must submit abatement certi?cation and documentation, required within 10 days after abatement date. The certi?cation shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records. ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM Date By Which Violation Must be Abated: 06/20/2019 Proposed Penalty: 811934.00 See pages 1 through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page 9 of 38 OSHA-2 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Inspection Date(s): 11/26/2018 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Citation] Item4 Type ofViolation: Serious 29 CFR 1910.1 Information pertaining to the equipment in the process did not include material and energy balances for processes built after May 26, 1982: a) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to develop and compile process safety information related to material and energy balances for the E0 plant process streams, including the E0 reaction process, contributing to employee exposure to the toxic, ?re, and explosion hazards posed by ethylene oxide. Pursuant to 29 CFR 1903.19, the employer must submit abatement certi?cation and documentation, required within 10 days after abatement date. The certi?cation shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records. ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM Date By Which Violation Must be Abated: 06/20/2019 Proposed Penalty: $11934.00 See pages 1 through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Notification of Penalty Page 10 of 38 OSHA-2 U.S. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Inspection Date(s): 11/26/2013 - 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Citation] ItemS Type ofViolation: Serious 29 CFR 1910.1 The employer did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP): a) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, due to the in?ltration of EO into the E0 control building, employees who remained in the E0 control room to conduct emergency operations were exposed to toxic and explosion/?re hazards when the employer did not document that it complied with its chosen RAGAGEP, 752, Management of Hazards Associated with Location of Process Plant Permanent Buildings, Sections 7.6.2, 8.4.1 and 8.4.2. The E0 control building was not designated by the employer as a shelter-in~place and did not include equipment/building features that would have protected the control building, control equipment, and its employees from the in?ltration of E0 vapors such as: sensors in the air intakes to alert the occupants of the ingress of hazardous materials, means to automatically limit air ingress from HVAC systems in the event of a sensor alarm; appropriately sealed windows and doors equipment for operators who must remain in the control room, such as a breathing air manifold system with supplied air masks, or SCBAs, and, equipment to facilitate an escape, if warranted, such as 5? or 10-minute escape packs that would provide enough clean air to allow the operators to evacuate to a safe location. b) Ethylene Oxide Batch Plant, Croda, Inc. On or about November 25, 2018, the employer failed to document it complied with its chosen RAGAGEP, ASME B313 (2016), Process Piping, Section 335.2.2, Bolting Torque when it assembled piping ?anges in ethylene oxide service that were not torqued to their proper design loading including the ?ange bolts on the 1&frac] 2; inch vent line of the Puri?cation Column Steam Reboiler E-430 in Area 400 that was involved in the ethylene oxide release. In addition, approximately 85 other ?anges were found post-incident to be under torqued in Areas 400 and 1400 of the E0 plant. 0) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to document it complied with its chosen recognized and RAGAGEP, ASME 831.3 (2016), Process Piping, Section 308.4 Gaskets, when it assembled a piping ?ange with a gasket that was not suitable for the process conditions, i.e. the gasket material was not compatible for ethylene oxide service. This piping ?ange and gasket were part of the 1&fra012; inch vent line of the Puri?cation Column Steam See pages 1 through 4 of this Citation and Notification of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page 11 of 38 OSHA-2 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Date(s): 11/26/2013 - 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Reboiler E-430 in Area 400 that was involved in the release of ethylene oxide. d) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to document it complied with RAGAGEP, such as ASME (2013), Guidelines for Pressure Boundary Bolted Flange Joint Assembly, Section 8.1, Installation of Bolts, when it installed bolts for assembly of a piping ?ange, that were made of B7 Alloy material and did not meet the bolt design speci?cation which required B8 stainless steel bolts for the application per specification. This piping ?ange and incorrect bolting materials were used on the 1&fra012; inch vent line located on the Puri?cation Column Steam Reboiler, in Area 400 that was involved with the release of ethylene oxide. e) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer did not document that it complied with RAGAGEP such as: NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection Sections 7.1.10.3, 7.5.2, 9.2.1, and 9.2.2 for ?xed water spray systems (deluge system); NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection Sections 4.6.4.1 and 4,6.2 for diesel ?rewater pumps and jockey pump; API 2510 [as referenced in employers chosen RAGAGEP, the Ethylene Oxide Product Stewardship Manual Third Edition Section 10.3.1.5 requires 4 hour ?rewater supply; and, NFPA 22, Standard for Water Tanks for Private Fire Protection Section 4.1.1 for ?rewater tank; when the existing ?rewater system was not adequately sized and designed to meet the additional ?rewater demands g. simultaneous operation of deluge system and ?re monitors, and other non-?rewater users) for mitigating an ethylene oxide release at the Plant. This contributed to the ?rewater supply being undersized for a high ?rewater demand case involving ?ow from multiple users. These conditions contributed to employee exposure to the toxic, ?re, and explosion hazards posed by ethylene oxide. Pursuant to 29 CFR 1903.19, the employer must submit abatement certi?cation and documentation, required within 10 days after abatement date. The certi?cation shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records. See pages I through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page 12 of 38 OSHA-2 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Inspection D3336): 11/26/2018 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM Date By Which Violation Must be Abated: 06/20/2019 Proposed Penalty: $11934.00 See pages I through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Notification of Penalty Page 13 of 38 OSHA-2 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Inspection Date(s): 11/26/2013 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Citation 1 Item 6 Type ofViolation: Serious 29 CFR 1910.] The process hazard analysis did not address engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases: a) Ethylene Oxide Batch Plant, Croda, Inc. On or about November 25, 2018, the employer failed to address the need for an effective advanced warning ethylene oxide area detection system for employees required to investigate an ethylene oxide release. b) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employers facility siting study (Croda Atlas Point Facility Siting Study Revised Report, November 2, 2015) identified that the E0 Control Room was in an area of potential toxic release consequences/hazards, however, neither the facility siting report or the 2016 Updated PHA included engineering controls equipment/building features) such as, but not limited to, the following: · sensors in the air intakes to alert the occupants of the ingress of hazardous materials, · means to automatically limit air ingress from HVAC systems in the event of a sensor alarm; · appropriately sealed windows and doors · appropriate or · administrative controls such as emergency procedures that designate the building as a place to immediately evacuate upon detection/noti?cation of a toxic/?ammable materials release. 0) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to address the adequacy of the ?rewater supply with respect to the deployment of the water deluge systems and ?rewater monitors to contain and quell a release of ethylene oxide. These conditions contributed to employee exposure to the toxic, ?re, and explosion hazards posed by ethylene oxide. Pursuant to 29 CFR 1903.19, the employer must submit abatement certi?cation and documentation, required within 10 days after abatement date. The certi?cation shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that See pages 1 through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and reSponsibilities. Citation and Noti?cation of Penalty Page 14 of 38 OSHA-2 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Inspection Datetsh 11/26/2018 - 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records. ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM Date By Which Violation Must be Abated: 06/20/2019 Proposed Penalty: $11934.00 See pages 1 through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page 15 of 38 OSHA-2 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Inspection Date(s): 11/26/2018 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Citationl Item7 Type ofViolation: Serious 29 CFR The process hazard analysis did not address facility siting: a) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to address the impact of toxic releases on the ECO Plant Control Building, a critical building that is occupied by operators, who conduct emergency operations. This building was not designed as a shelter- in-place location for protecting employees from toxic exposure to ethylene oxide during an emergency release. b) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to address a suitable location for the nitrogen purge valves or a suitable means to activate these manual valves in the event of an emergency release that prevented operators from accessing these valves. These conditions contributed to employee exposure to the toxic, ?re, and explosion hazards posed by ethylene oxide. Abatement Note: Feasible means of abatement of this hazard could include relocating the manual nitrogen purge valve to a safe, accessible location or consider installing an automatic nitrogen sweeping system valves and instrumentation) to allow for remote de-inventory of the from the DCS. Pursuant to 29 CFR 1903.19, the employer must submit abatement certi?cation and documentation, required within 10 days after abatement date. The certi?cation shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records. ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM Date By Which Violation Must be Abated: 06/20/2019 Proposed Penalty: $11934.00 See pages 1 through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page to of 38 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Inspection Date(s): 11/26/2018 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalgi Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 See pages 1 through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page 1? of 38 OSHA-2 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Date(s): 11/26/2013 - 05/ 23/ 2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Citationl Item8 Type ofViolation: Serious 29 CFR The process hazard analysis did not address human factors: a) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employers process hazard analysis failed to address human factors relating to the confusing displays on the Control Room Distributed Control System user-machine interface Human Machine Interface) for activating the ?rewater deluge system resulting in operator errors, such as the erroneous activation of incorrect deluge systems during an emergency release, contributing to employee exposure to ethylene oxide. Pursuant to 29 CFR 1903.19, the employer must submit abatement certi?cation and documentation, required within 10 days after abatement date. The certi?cation shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records. ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM Date By Which Violation Must be Abated: 07/12/2019 Proposed Penalty: 811934.00 See pages 1 through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities, Citation and Noti?cation of Penalty Page 18 of 38 OSHA-2 U.S. Department of Labor InSpection Number: 1361878 Occupational Safety and Health Administration Date(s): 11/26/2018 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Citationl Item9 Type ofViolation: Serious 29 CFR 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 that addressed emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to quali?ed operators to ensure that emergency shutdown is executed in a safe and timely manner: a) Ethylene Oxide Batch Plant, Croda, Inc. On or about November 25, 2018, the employer failed to develop and implement written operating procedures to de-inventory the ethylene oxide from equipment, such as (but not limited to) that contained in the Puri?cation Tower (T-430), to divert ethylene oxide away from Puri?cation Column Steam Reboiler E-43 0, the location of the compromised ?ange leaking ethylene oxide, contributing to employee exposure to ethylene oxide. Pursuant to 29 CFR 1903.19, the employer must submit abatement certi?cation and documentation, required within 10 days after abatement date. The certi?cation shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records. ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM Date By Which Violation Must be Abated: 06/20/2019 Proposed Penalty: 811934.00 See pages I through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page 19 of 38 U.S. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Date(s): 11/26/2018 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Citationl Item 10 Type ofViolation: Serious 29 CFR The employer did not deveIOp and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information that addressed emergency operations: a) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to develop and implement written operating procedures to identify the correct deluge system(s) to activate in the event of an ethylene oxide leak. b) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to develop and implement written operating procedures to follow in order to manage ?rewater supply during its use in an emergency. These conditions contributed to employee exposure to the toxic, ?re, and explosion hazards posed by ethylene oxide. Pursuant to 29 CFR 1903.19, the employer must submit abatement certi?cation and documentation, required within 10 days after abatement date. The certi?cation shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records. ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM Date By Which Violation Must be Abated: 06/20/2019 Proposed Penalty: $11934.00 See pages 1 through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page 20 of 38 OSHA-2 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration 1113139015011 Date(s): 11/26/2018 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Citation 1 Item 11 Type of Violation: Serious 29 CFR The employer did not train each employee in the operating procedures as speci?ed in paragraph of 29 CFR 1910.119: a) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to train employees on how to manage ethylene oxide leaks. b) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to train employees on how to use ?re protection systems; 0) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to train employees on the correct use and activation of the water deluge system; and, d) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to train employees on the consequences of deviation with respect to effective measures to mitigate hazards. The hazardous conditions listed in the above instances exposed employees to toxic, ?re, and explosion hazards posed by ethylene oxide. Pursuant to 29 CFR 1903.19, the employer must submit abatement certi?cation and documentation, required within 10 days after abatement date. The certi?cation shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records. ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM Date By Which Violation Must be Abated: 06/20/2019 Proposed Penalty: 811934.00 See pages 1 through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page 2] of 38 OSHA-2 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Inspection Date(s): 11/26/2013 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Citation] Item 12 Type ofViolation: Serious 29 CFR Construction and equipment was not in accordance with design speci?cations: a) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employers PSSR failed to assure that the ?ange joint assembly for the 1 ½-inch-diameter vent line on the Puri?cation Column Steam Reboiler (E-430) in Area 400 was installed/constructed in accordance with design speci?cations with respect to ?ange assembly the gasket and bolt material of construction, and the bolt torqueing did not meet the design speci?cation), resulting in failure of the ?ange assembly and employee exposure to ethylene oxide. Pursuant to 29 CFR 1903.19, the employer must submit abatement certi?cation and documentation, required within 10 days after abatement date. The certi?cation shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records. ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM Date By Which Violation Must be Abated: 08/02/2019 Proposed Penalty: 531193400 See pages 1 through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page 22 of 38 OSHA-2 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Inspection Date(s): 11/26/2018 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penal_ty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Citationl Item 13 Type ofViolation: Serious 29 CFR The pre-startup safety review did not con?rm that safety, operating, maintenance, and emergency procedures were in place and were adequate prior to the introduction of highly hazardous chemicals into a process: a) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to assure that Control Room evacuation procedures in the event of toxic ethylene oxide in?ltration were developed and implemented to minimize employee exposure to ethylene oxide. b) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to assure that emergency operating procedures were developed and implemented to mitigate an ethylene oxide leak including speci?c steps to isolate/de-inventory quantities of ethylene oxide to a safe location. 0) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to assure that written[HA?O2] procedures were developed and implemented for 1) the operation of the deluge systems in the Control Room and, 2) for managing ?rewater usage, were in place and adequate. d) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to assure that written procedures were developed and implemented which would enable connection to other ?rewater make?up sources, such as to Suez water, in order to maximize available water supply during an emergency release. e) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to assure that written procedures were developed and implemented for operating the ?re pumps and ?re water tank at the Powerhouse. The hazardous conditions listed in the above instances exposed employees to toxic, ?re, and explosion hazards posed by ethylene oxide. Pursuant to 29 CFR 1903.19, the employer must submit abatement certi?cation and documentation, required within 10 days after abatement date. The certi?cation shall include a statement that abatement See pages 1 through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page 23 of 38 OSHA-2 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Inspection D3te(5)= 11/26/2013 - 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records. ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM Date By Which Violation Must be Abated: 07/12/2019 Proposed Penalty: $11934.00 See pages I through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page 24 of 38 OSHA-2 US. Department of Labor Inspection Number: 1361878 Occupational Safety and Health Administration Inspection Date(s): 11/26/2018 - 05/23/2019 Issuance Date: 05/24/2019 Citation and Noti?cation of Penalty Company Name: Croda Inc Inspection Site: 315 Cherry Lane, New Castle, DE 19720 Citationl Item 14 Type ofViolation: Serious 29 CF The pre-startup safety review did not con?rm that for new facilities, a process hazard analysis (PHA) was completed before startup; a) Ethylene Oxide Batch Plant, Croda, Inc. - On or about November 25, 2018, the employer failed to perform a ?nal process hazard analysis to ensure that all hazards were identi?ed, evaluated and controlled before startup. The FHA update in 2016 did not identify process hazards such as how the ?rewater system did not take into account the ?ow from multiple users when designing the system for the maximum ?rewater demand. In addition, the DCS graphical interface for the ?rewater deluge system was dif?cult to understand resulting in the incorrect deluge system being activated, the control building was not designed to prevent toxic vapor ingress, and the nitrogen purge system for the 430 E0 Puri?cation Column could not be accessed during an E0 release, resulting in employee exposure to ethylene oxide. Pursuant to 29 CFR 1903.19, the employer must submit abatement certi?cation and documentation, required within 10 days after abatement date. The certi?cation shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records. ABATEMENT DOCUMENTATION REQUIRED FOR THIS ITEM Date By Which Violation Must be Abated: 07/ 12/2019 Proposed Penalty: $11934.00 See pages 1 through 4 of this Citation and Noti?cation of Penalty for information on employer and employee rights and responsibilities. Citation and Noti?cation of Penalty Page 25 of 38