OSHA initiated a PSM inspection under the agency’s Site Specific Targeting program for industries with high injury and illness rates and its Process Safety Managed Covered Chemical Facilities National Emphasis Program. Eight of the 15 serious violations are related to the Process Safety Management Program for the maintenance and operation of the Anhydrous Ammonia refrigerant system to prevent potentially catastrophic releases. The violations include failing to inspect and test equipment intended to control and contain ammonia; failing to maintain process equipment in an acceptable working order; and not ensuring that process information is up to date and accurate. The company was also cited for failing to provide emergency eyewash, not having an audiometric testing program, and improper chemical storage. Proposed penalties are $76,500. Here is a breakdown of the citations:
NOTE: Anyone in the refrigeration industry following “IIRA/ASME-15”? LOL, there is one citation that will be thrown-out! There are a few other “odd” citations such as Citation 1 Item 1 for not having a exhaust fan switch outside the engineroom was a “general duty clause” citation????
Citation 1 Item 1
Type of Violation: Serious; $6,300
Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which was free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to toxic atmosphere and fire hazards:
At this job site, the employer did not ensure the control switch for the exhaust fan was located outside the engine room. In the event of a release of ammonia, employees were not able to remotely engage the exhaust fans, potentially exposing them to excessive levels of ammonia or a fire.
Among other methods, one feasible means of abatement is to follow the ASHRAE standards and install a control switch for exhaust fan outside ammonia engine room.
Citation 1 Item 2
Type of Violation: Serious; $ 4,500
29 CFR 1910.95(g)(1): The employer did not establish and maintain an audiometric testing program as provided by 29 CFR 1910.95(g) by making audiometric testing available to all employees whose exposures equal or exceed an 8-hour time-weighted average of 85 decibels:
At this job site, employees working in Production 1, Repacking 2, and the warehouse were exposed to noise levels in excess of90 dBA, as an 8-hour time-weighted average. The employer had not provided audiometric testing for exposed employees in these areas.
Citation 1 Item 3
Type of Violation: Serious; $6,300
29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices:
In the ammonia engine room, the engine room access door and a garage door leading into the engine room were not each equipped with a tight-fitting seal, exposing employees outside the room to potential leaks of ammonia. The doors did not comply with the employers accepted engineering practice, ANSI/ ASHRAE Standard 15 requirements.
Citation 1 Item 4
Type of Violation: Serious; $6,300
29 CFR 1910.119(g)(1)(i): The employer did not train each employee in the operating procedures as specified in paragraph (f) of 29 CFR 1910.119:
At this job site, the employer did not ensure each employee involved in the operating process was trained in those operating processes such as but not limited to:
- VICS-SOP-10 Ammonia delivery
- VICS-SOP-11 Line opening
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 5a
Type of Violation: Serious; $6,300
29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment:
The employer did not develop and implement mechanical integrity program procedures for the inspection, testing, and repairing of insulated ammonia refrigeration process vessels and piping.
The hazard was observed in ammonia engine room, when the employer continued to operate vessels and piping that had physical damage and or missing insulation.
Citation 1 Item 5b
Type of Violation: Serious; Grouped
29 CFR 1910.119(j)(4): Inspection and testing was not performed on process equipment:
At this job site the employer did not inspect and test insulated Ammonia refrigeration process vessel and piping. This hazard was observed in the Ammonia engine room, when the employer allowed vessels and piping to continue to operate with damaged and/or missing insulation without inspecting and testing the system for damaged insulation and or potential leaks.
Citation 1 Item 6
Type of Violation: Serious; $6,300
29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment was not consistent with applicable manufacturers’ recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience:
At this facility in the ammonia engine room, the employer failed to test, inspect or document the tests and inspections in accordance with manufacturers’ recommendations on the process equipment, such as, but not limited to:
- ammonia alarm system calibration and testing
- sensors for ammonia alarm system
Citation 1 Item 7
Type of Violation: Serious; $6,300
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:
At this job site, the employer failed to document and maintain inspection and test records on process equipment, such as, but not limited to:
- Vessel Annual inspection
- Compressor Annual
- Condenser and Evaporator
- Valves Piping and Controls
Citation 1 Item 8
Type of Violation: Serious; $6,300
29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits before further use:
At this job site, the employer did not correct deficiencies in the ammonia refrigeration process equipment, such as, but not limited to:
- insulation and ensuring that large ice deposits on the surfaces were not due to anhydrous ammonia leaks.
- Relief valve discharge located directly located next to walkway.
Citation 1 Item 9
Type of Violation: Serious; $6,300
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:
The employer did not have updated and current piping and instrumentation diagrams (P&ID) for the ammonia engine room. The P&IDs in use had errors such as but not limited to:
- VLR-2 shut off valve coming off pump not shown on drawing VICS/P&ID-02
- V-6 HPR-1 relief valve was not on drawing VICS/P&ID-01
- EV-34 make, model, and unit number were not correct on drawing VICS/P&ID-01
Citation 1 Item 10
Type of Violation: Serious; $4,500
29 CFR 1910.134(e)(1): The employer did not provide a medical evaluation to determine the employee’s ability to use a respirator, before the employee was fit-tested or required to use the respirator in the workplace:
At this job site, the operator working in ammonia refrigeration cold storage warehouse was not given a medical evaluation prior to working with ammonia and using an air-purifying respirator, exposing employee to respiratory hazards.
Citation 1 Item 11
Type of Violation: Serious; $3,600
29 CFR 1910.134(f)(2): Employee(s) using tight-fitting facepiece respirators were not fit-tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) was used, and at least annually thereafter:
At this job site, the operator worked in ammonia refrigeration cold storage warehouse and was not given a fit-test prior to working with ammonia and using an air-purifying respirator, exposing the employee to respiratory hazards.
Citation 1 Item 12
Type of Violation: Serious; $3,600
29 CFR 1910.151(c): Where employees were exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use:
At this facility, employees worked with hazardous chemicals and were not provided with adequate facilities for eye flushing.
Citation 1 Item 13
Type of Violation: Serious; $6,300
29 CFR 1910.307(c)(2)(i): Equipment in hazardous (classified) location(s) was not approved for the ignitable or combustible properties of the specific gas, vapor, dust, or fiber that was or could be present:
At this facility in the ammonia engine room, the ventilation system did not meet IIRA/ASME-15 standards when exhaust fans were not running continuously. Lack of adequate ventilation required electrical equipment in the room to be approved for Class 1, Division 2 locations. The electrical equipment, including lighting and other electrical devices, were not designed for Class 1, Division 2 hazardous locations. Employees working in or near these areas were exposed to fire and explosion hazards.
Citation 1 Item 14
Type of Violation: Serious; $3,600
29 CFR 1910.1200(a)(1): The employer did not effectively ensure that the information concerning the hazards of all chemicals to which the employees may be exposed to, was transmitted as accomplished by the means of the employer’s comprehensive hazard communication programs including labeling and other forms of warning, material safety data sheets and employee training:
At this job site in the dry area, the employer did not ensure chemical storage of incompatible chemicals were kept separate, exposing employees to possible inhalation hazards.