This appears to be an inspection after an ammonia leak in a food processing area that impacted a contractor and food production workers. A contractor drilled into what was thought to have been an “abandoned line” releasing the ammonia. The leak was on 12/3/11 and the inspection began on 12/12/11. Some very enlightening citations for refrigeration process safety managers to contemplate! PLEASE NOTE: these are INITIAL and the plant has not yet responded to them; HOWEVER, this posting is meant to shed light on what an OSHA CSHO will be looking at after a release of an HHC.
These citations are so EASY to see how they were discovered! The CSHO just went to the point of release and worked backwards. These are a SUMMARY of the actual citations issued on 5/31/12: Click Here (pdf) to see the actual citation.
- PSI did not contain relief system design and design basis for 29 RVs ($7K):
- No documentation the equipment met RAGAGEP – pipe was color coded but no content, state, or flow direction missing, valves not uniquely labeled/marked ($7K);
- PHA did not address failure of ECs and ACs ($7K);
- PHA not updated every five years ($7K);
- No SOP for draining two oil pots or charging system ($7K);
- SOPs do not reflect actual practices of pump outs ($5.5K); not following the Line Break SWP/Permit ($7K);
- Operators not receiving training on SOPs ($7K);
- Training documentation did not contain required data nor the means used to verify knowledge ($7K);
- Contractors not trained on the facility emergency action plan ($7K) PLEASE NOTE the contractor was working in a FOOD PRODUCTION area and NOT the engine room!;
- No written MI program for 12 relief valves ($7K);
- NO MI documentation showing inspection/testing done on 26 relief valves;
- Hotwork procedures and permit does not meet 1910.252(a) and the facility did not follow their HW procedures and permit requiring the equipment to be purged before HW begins ($7K);
- Written MOC procedures did not ensure technical basis of changes were considered; the change involved replacing an undersized RV and the MOC did not contain piping or RV sizing documentation ($7K for all the MOC findings).
- Written MOC procedures did not ensure impacts on safety and health of changes were considered; the change involved abandoned piping.
- Written MOC procedures did not ensure SOPs were updated; two (2) specific MOCs called out:
- installed new control panels for compressors and SOPs were not updated to reflect these new controls
- major re-piping on two pieces of equipment and SOPs were not updated to reflect these changes
- Written MOC procedures did not ensure authorization requirements were addressed before a change; four (4) MOCs did not have authorization from “Safety”, Plant and Utility Managers”.
- Compliance Audits not done every three years ($3.3K)
- Not documenting closure of findings from a 2008 audit ($7K); five (5) specific items called out:
- Contractor Evaluations
- Hotwork Deficiencies
- Incomplete PSI
- missing documentation for closure of previous audit items
- Not doing PSSRs
- ERP did not contain a listing of emergency PPE, locations where it maintained, nor the circumstances requiring it to be worn ($7K);
- Response Team PPE not included in any inspection program nor procedures for inspection/testing;
- ERP does not require legs, arms, toroso protection from NH3 exposure;
- SCBA’s used by responders who wear prescription eyewear not equipped with corrective lenses ($4.4K)
- Facial Hair and respirators ($5.5K)
- No LOTO machine specific procedures for Compressors ($7K);
- NO EW/SS in locations where operators are exposed to corrosive materials ($5.5K)