OSHA cites food plant with REPEAT PSM citations (NH3 & $121K)

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OSHA has cited a processor of chicken, beef and pork for repeat and serious violations of workplace safety standards following an inspection at a NY manufacturing plant. The proposed fines total of $121,720. The inspection, which began on May 15, was conducted under OSHA’s Site Specific Targeting Program, which directs enforcement resources to high-hazard workplaces with the highest rates of injuries and illnesses. OSHA found a cross section of mechanical, electrical and fall hazards, as well as several deficiencies in the plant’s process safety management program for its refrigeration system that uses ammonia. These conditions resulted in the issuance of 11 serious citations with $61,000 in fines and three repeat citations were issued with $60,720 in fines.  There are a couple of NOTABLE citations that should garner MUCH ATTENTION in the refrigeration industry:

1) RV discharge distance is measured by work platforms and NOT merely from the roof.  One of the REPEAT citations was associated with RV discharge not being over 15′ above the condenser platforms.

2) SOP details MEAN A LOT… SOPs with incomplete sentences, referencing non-existing equipment and documents NOT associated with the plant.  Interviews with engineers and operators indicated no one knew what the SOPs were meant to say or what equipment they were referencing.

Folks – using another facility’s SOPs is a STARTING POINT.  And although many traditional safety programs can be revised using the “Find and Replace” function within WORD; PSM operating procedures are NOT that easily adopted into a facility specific operating procedures.  It looks like OSHA is actually reading SOPs in their inspections!  Keep in mind, the inspector/auditor does not need to be an “expert” in your process to have the ability to identify incomplete sentences in the SOP or identify equipment that is not listed in the PSI.  And to top it off, when they ask the very workers who operate/maintain the process about these discrepancies and no one can explain them; we have just sunk our battleship!  Here is a breakdown of the citations:

Citation 1 Item 1

Type of Violation: Serious; $5500.00

29 CFR 1910.23(a)(3)(i): Every hatchway and chute floor opening were not guarded by one of the following: Hinged floor opening cover of standard strength and construction equipped with standard railings or permanently attached thereto so as to leave only one exposed side. When the opening is not in use, the cover shall be closed or the exposed side shall be guarded at both top and intermediate positions by removable standard railings: a) On or about 05/16/13, on the roof above boiler room, a hatchway’s cover was open exposing employees to approximately 18 feet fall below.

Corrected During Inspection

 

Citation 1 Item 2

Type of Violation: Serious; $5500.00

29 CFR 1910.23(a)(4): Skylights were not guarded by a standard skylight screen or a fixed standard railing on all exposed sides.

On or about 05/16/13, on the roof near refrigeration equipment such as, but not limited to: RTU-3 and RTU-5, Twelve (12) skylights did not have screen guards or standard railings.

Corrected During Inspection

 

Citation 1 Item 3

Type of Violation: Serious; $3300.00

29 CFR 1910.37(a)(3): Exit routes were not free and/or unobstructed. No materials or equipment may be placed, either permanently or temporarily, within the exit route:

  1. On or about 05/16/13, in the pack 2/3 room, an exit route (exit #11) was blocked by two metal supports for a plastic container and a plastic bag with sausages.
  2. On or about 05/16/13, in the pack2/3 room, an exit route (palletizing #3, Fl03) was blocked by a plastic bag on a metal support.

 

Citation 1 Item 4

Type of Violation: Serious; $7000.00

29 CFR 1910.119(d)(3)(i)(B): The employer’s piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process:

  1. On or about 05/16/13, in the establishment, Piping and Instrument Diagram P&ID-AU 16 and CB ALKAR, dated: 6/01/2007, DWG NO: BU-30-73-052, did not represent the existing process equipment Oil Pot of CB ALKAR, Installation Date: 08/2010, Manufacturer: H.A. Phillips, Maximum Operating Pressure/Temperature: 300 psi@ -20 F, National Board Number: 12464, Dimensions: 29″x 6-5/8″.
  2. On or about 05/16/13, in the establishment, Piping and Instrument Diagrams P&IDs dated 6/01/2007 such as, but not limited to:
    1. P&ID: AU 16 and CB ALKAR, DWG NO: BU-30-73-052
    2. P&ID: +12F RECIRC. PUMP PKG, DWG NO: BU-13-73-008
    3. P&ID: 800GL COMPRESSOR RC-5, DWG NO: BU-13-73-020
    4. P&ID: AUTO PURGERAP-1 AND LOW TEMP PUMP RECEIVER PR-1, DWG NO: BU-13-73-030 did not include information that provided specific identification of process equipment such as valves. There were many valves without tag numbers.
  3. On or about 05/16/13, in the establishment, Piping and Instrument Diagram P&ID: DOUBLE ALKAR CHILLER, dated: 06/01/2007, DWG: BU-29-73-041 was not accurate as represented an Oil Pot, Manufacturer: EVAPCO, Maximum Operating Pressure/Temperature: 300 psig/-20 F to 500 F, instead of representing the existing Oil Pot, Installation Date: 9/14/2008, Manufacturer: Standard Refrigeration Company, Maximum Operating Pressure/Temperature: 400 psi @ -20F.

 

Citation 1 Item 5

Type of Violation: Serious; $7000.00

29 CFR 1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process:

  1. On or about 05/16/13, throughout the facility, Process Hazard Analysis (PHA) for Ammonia Refrigeration System (dated 07 /22/2004 and Revalidation 2009) did not evaluate employees exposure to toxic Ammonia while performing maintenance tasks on the roof and other equipment’s platforms located near to the discharge of relief piping from process equipment such as, but not limited to:
    1. Pump Out Vessel, 
    2. Pump Out Compressor, 
    3. Double Wide Alkar, 
    4. Little Alkar and
    5. Evaporator Condensers EC# 3 and EC#4.

 

Citation 1 Item 6 

Type of Violation: Serious; $7000.00

29 CFR 1910.119(f)(1)(i)(B): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and did not address normal operations:

  1. On or about 05/16113, in the establishment, operating procedures for each oil draining point such as, but not limited to:
    1. Oil Draining Procedure of Oil Pot for CB-Alkar-Chiller Surge Drum,
    2. Oil Draining Procedure of Oil Pot for Double Alkar Chiller Surge Drum and
    3. Oil Draining Procedure for Drain Point of Pumpout Vessel and Compressor, were not developed.
  1. On or about 05/16/13, in the establishment, Standard Operating Procedures (SOPs) such as, but not limited to:
    1. SOP +12F REC – Operation of Recirculator & Ammonia Pumps, and
    2. SOPCB-ALKAR-CHILLER – Operation of Water Chiller & Control Bank did not provide clear instructions and were not accurate as evidenced by:
      1. SOP +12F REC – Operation of Recirculator & Ammonia Pumps mentioned valve tag numbers and a P&ID which did not exist in the plant. Examples were:
        1. In page 14, Task 1. Initial Startup, Step 5 and in pages 20, 21, Task 8a. Pump out of liquid pump #1, Steps 3, 5, 8, and 10, a non-existent valve XXXX2 was mentioned.
        2. In pages 25, 26, Task 9. Pump out Vessel and Pumps, Steps 12, 20, 22, another non-existent valve xxxx was mentioned. Engineers who operated and maintained the Ammonia System did not know which valves these steps were referring to and the valves XXXX2 and xxxx were not found in any P&ID.
        3. In addition, in page 26, this SOP mentioned P&ID CV-13-73-025 which did not exist in this plant. SOP-CB-ALKAR-CHILLER- Operation of Water Chiller & Control Bank clicl not use valve tag numbers in all their steps and some of the steps were incomplete sentences making unclear the actions needed to be taken by employees.
          1. Examples were:
            1. In page 8, Task 1. Initial Startup, Step 4 – “Confirm.that all line service valves are open EXCEPT high pressure liquid valves and high suction and”. This step was an incomplete sentence and it did not use valve tag numbers.
            2. In page 12, Task 4. Emergency Shutdown, Step 2 – “Close liquid valves and suction valves and”. This step was an incomplete sentence and it did not use valve tag numbers.
            3. In page 13, Valve Legends, there were not valves called “line service valves, high pressure liquid line valves and high side suction” as used in Step 4, page 8.
            4. In page 9, Steps 12, 13 mentioned “Open Suction valve” and “Open Liquid valve”. These steps did not specify which valves tag numbers needed to be open.
            5. Many steps stated see P&ID # BU-30-73-052 as a reference to properly apply this SOP. However, this P&ID was not up to date, it had missing valve tag numbers and an existing equipment (Oil Pot). Also, this SOP mentioned valves: AMM 1397 and AMM 1398 which were not in the corresponding P&ID # BU-30-73-052. 

Citation 1 Item 7

Type of Violation: Serious; $7000.00

29 CFR 1910.119(J)(4)(i): The employer did not perform inspection and tests on process equipment to maintain its mechanical integrity:

  1. On or about 05/16/13, throughout the Ammonia Refrigeration Facility, Employer did not perform testing of High Level Alarms/High Level Emergency Shutdown Systems and Low Level Emergency Shutdown Systems (HLS FSl; LSH 13022), on process equipment such as, but not limited to:
    1. High Temp Recirculator and Low Temp Pump Receiver, at least annually as required by HAR Bulletin #110-1993, Section 6.6.4 and the Employer’s Preventive Maintenance/Mechanical Integrity Procedures.
  2. On or about 05/16/13, throughout the Ammonia Refrigeration Facility, Employer did not perform testing (i.e. Ultrasonic Non-Destructive Testing) on process equipment installed in 2005 such as, but not limited to:
    1. High Temperature Recirculator (except bottom);
    2. High Temperature Recirculator Oil Pot;
    3. Evaporative Condensers EC-3 and EC-4;
    4. High Temperature Recirculator Transfer Tank, Pumpout Vessel and Pumpout Compressor;
    5. Alkar Chiller and Surge Drum;
    6. Spiral Freezers SPC-A, SPC-B and SPC-C;
    7. Denetting Coolers DC-Al and DC-A2;
    8. South Hallway Units SH-Al and SH-A2;
    9. Slicing Coolers Units SC-Al, SC-Bl, SC-B2;
    10. East Hallway Units EH-Al and EH-A2;
    11. Blast Cooler Units BC-Bl, BC-B2, BC-Al, BC-A2;
    12. Finish Cooler Units FBC-Al and FBC-A2;
    13. Fresh Blast Cooler Units FBC-Bl, FBC-B2, FBC-A3;
    14. Spiral Cooler Pack Room Units PR-Al and PR-Bl;
    15. Cooler Pack Room Unit CIP-Al;
    16. Cooler# 4 Units AU-40 and AU-41 at least every 5 years as required by IIAR Bulletin #110, 1993, Section 6.4.4. and Employer’s Preventive Maintenance/Mechanical Integrity Procedures.
  3. On or about 05/16/13, in the electrical room adjacent to the engine room, Employer did not perform testing of the Honeywell HA-40 Ammonia Detection/Alarm System every 3 months as required by Manufacturer and Employer’s Preventive Maintenance/Mechanical Integrity Procedures.

Among abatement methods is to follow IIAR Bulletin #110-1993, Section 6.4A, Section 6.6.4 and Manufacturers Recommendations.

 

Citation 2 Item 1

Type of Violation: Repeat; $22,000.00

29 CFR 1910.23(a)(8): Every floor hole into which persons can accidentally walk were not guarded:

  1. On or about 05/16113, on the plant’s roof/old condensers’ platforms, there were two holes measuring 9 Inches and 9.3 inches exposing employees to trips and falls. Businees was previously cited for a violation of this occupational safety and health standard or its equivalent standard 29 CFR 1910.23 (a)(8), which was contained in OSHA inspection number 312217144, citation number 1, item number 1 and was affirmed as a final order on 10/02/2008, with respect to a workplace located in MO

Corrected During Inspection

 

Citation 3 Item 1

Type of Violation: Repeat; $38,500.00

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices:

  1. Recent examples of this occurred on 05/16/13, when: a) On the Plant’s roof, Employer did not document that the relief piping discharge from Pump Out Vessel which extended 10.2 feet above adjacent roof floor complied with, standards such as, but not limited to ANSI/ASHRAE 15-2010: Safety Standard for Refrigeration Systems, Section 9. 7.8; ANSI/IIAR 2- 2008: Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration System, Section 11.3.6.4, requiring the discharge from relief devices to the atmosphere shall not be less than 15 feet above adjacent grade, ground, platform or roof level.
  2. On the Plant’s roof, Employer did not document that the relief piping discharge from Pump Out Compressor which extended 10.8 feet above adjacent roof floor complied with, standards such as, but not limited to: ANSl/ASHRAE 15-2010: Safety Standard for Refrigeration Systems, Section 9.7.8; ANSI/llAR 2-2008: Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration System, Section 11.3.6.4, requiring the discharge from relief devices to the atmosphere shall not be less than 15 feet above adjacent grade, platform or roof level.
  3. On the Plant’s roof, Employer did not document that the relief piping discharge from Double wide Alkar which extended 13.8 feet above adjacent roof floor complied with, standards such as, but not limited to: ANSI/ASHRAE 15-2010: Safety Standard for Refrigeration Systems, Section 9.7.8; ANSI/IIAR 2- 2008: Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration System, Section 11.3.6.4, requiring the discharge from relief devices to the atmosphere shall not be less than 15 feet above adjacent grade, platform or roof level.
  4. On the Plant’s roof, Employer did not document that the relief piping discharge from Little Alkar which extended 13.8 feet above adjacent roof floor complied with, standards such as, but not limited to: ANSI/ASHRAE 15-2010: Safety Standard for Refrigeration Systems, Section 9.7.8; ANSI/IIAR 2-2008: Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration System, Section 11.3.6.4, requiring the discharge from relief devices to the atmosphere shall not be less than 15 feet above adjacent grade, platform or roof level.
  5. On the top platforms of Evaporative Condensers EC#3 and EC#4, Employer did not document that the relief piping discharge from pressure relief valves: PSV 13145 and PSV 13146 above adjacent platform complied with, standards such as, but not limited to: ANSl/ASHRAE 15-2010: Safety Standard for Refrigeration Systems, Section 9.7.8; ANSI/HAR 2-2008: Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration System, Section 11.3.6.4, requiring the discharge from relief devices to the atmosphere shall not be less than 15 feet above adjacent grade, platform or roof level.

Business was previously cited for a violation of this occupational safety and health standard or its equivalent standard 29CFR 1910.119(d)(3)(ii), which was contained in OSHA inspection number 314060807, citation number 1, item number 2 and was affirmed as a final order on 01/28/2013, with respect to a workplace located in NE. Among feasible methods of abatement is to follow ANSI/ASHRAE 15-2010 and ANSI/IIAR 2-2008.

 

Citation 3 Item 2

Type of Violation: Repeat; $220.00

29 CFR 1910.303(g)(l)(i): The dimension of the working space in the direction of access to live parts operating at 600 volts or less and likely to require examination, adjustment, servicing, or maintenance while alive was less than indicated in Table S1: a) On or about 05/16/13, in the engine/compressors room, access to electrical control panel of the Pump Out Compressor (480 volts), disconnect for main power and disconnect for the heater were blocked by a utility cart with materials/equipment located in front of them. There was not a 3 feet clearance in front of these electrical panel/disconnect switches to provide sufficient access and working space to employees. Business was previously cited for a violation of this occupational safety and health standard or its equivalent standard 29 CFR 1910.303(g)(1), which was contained in OSHA inspection number 316034578, citation number 2, item number 1 and was affirmed as a final order on 06/25/2012, with respect to a workplace located in KS

 

 

NOTE to see citations associated with 29 CFR 1910.212(a)(1), 29 CFR 1910.333(a), 29 CFR 1910.335(a)(1)(i), please download the citation file below.

The citations can be viewed at https://www.osha.gov/ooc/citations/Tyson_Cits.pdf

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