OSHA has issued nine serious and two other-than-serious violations to a refrigeration warehouse after a January 2016 complaint investigation found the employer violated OSHA’s process safety management standard in regards to the anhydrous ammonia used in the facility’s refrigeration process where more than 10,000 pounds of ammonia are in use. An investigation by the agency’s area office found the company specifically failed to:
Citation 1 Item 1
Type of Violation: Serious; $4,000
29 CFR 1910.22(b)(1): Aisles and passageways were not kept clear and in good repair, with no obstruction across or in aisles that could create a hazard:
a) In October 2015, the employer was informed the evaporative condenser catwalk was unsafe. On January 14, 2016, OSHA observed the evaporative condenser catwalk was available for use with supports severely rusted or missing.
Citation 1 Item 2
Type of Violation: Serious; $5,000
29 CFR 1910.23(c)(1): Open-sided floors and/or platforms four feet or more above adjacent floor or ground level were not guarded with standard railings (or equivalent) and toeboards:
a) Employees conducting refrigeration system inspections, tests, preventative maintenance and repairs activities on the roofs of buildings were not provided roof edge fall protection. Fall distances ranged from 9 feet to over 30 feet.
Citation 1 Item 3
Type of Violation: Serious; $5,000
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:
a) P&ID R1.1 indicated a t-section junction with the 12 inch LSS pipe line, containing valve LTRP-01 and connecting to the Low Temp Accumulator, that joins the 12 inch LSS pipe line between the 5 inch LSS pipe line connecting to the “Removed From Service” Swing compressor SW-1 t-section junction and the 4 inch LSS pipe line connecting to the Booster Compressor B-1 t-section junction. The 12 inch LSS pipe line, containing valve LTRP-01 and connecting to the Low Temp Accumulator, actually joins the 12 inch LSS pipe line between the 5 inch LSS pipe line connecting to the Removed From Service Swing Compressor SW-1 t-section junction and the 5 inch LSS pipe line connecting to the Booster Compressor B-2 t-section junction.
b) P&ID R1.1 was missing a HPL pipe section that connected the HPL pipe section containing valve MTRP-1 101 and HPLpipe section containing valve MTRP-01 100. The missing HPLpipe section joins the first pipe section between valve MTRP-1 101 and the 2 inch HPL t-section junction. The missing HPL pipe section joins the second pipe section between valve MTRP-1 100 and the 2 inch HPL t-section junction.
c) P&ID R1.1 indicated a t-section junction with the 1.5 inch EQ pipe line, containing valve HPR-01 300, that joins with the 4 inch CD pipe line between valve HPR-1 104 and the t-section junction 1.5 inch HGD which contains valve AUX 305. The 1.5 inch EQ pipe line, containing valve HPR-01 300, actually joins the 1.5 HGD pipe line, containing valve AUX 305, between the t-section junction with the 4 inch CD pipe line and valve AUX 305.
d) P&ID R1.1 has two valves labeled LTRP-01 129. One valve labeled LTRP-01 129 is part of the LTRL piping for ammonia pump APOl and the other valve is part of the LTRL piping for ammonia pumpAP02.
e) P&ID R1.2 indicated a capped pipe section containing valve CE-01 600 joining the 0.75 inch HTRL pipe line between valves CE-01 100 and CE-01 101 within the piping associated with evaporator CE 01. The capped pipe section containing valve CE-01 600 was not physically present.
f) P&ID R1.2 indicated a capped pipe section containing valve CE-03 600 joining the 0.75 inch HTRL pipe line between valves CE-03 100 and CE-03 101 within the piping associated with evaporator CE 03. The capped pipe section containing valve CE-03 600 was not physically present.
g) P&ID R1.2 indicated a capped pipe section containing valve FE-01 600 joining the 0.75 inch LTRL pipe line between valve FE-01 102 and a t-section junction with the 0.75 inch HTRL pipe line containing valve FE-01 101 within the piping associated with evaporator CE 01. The capped pipe section containing valve FE-01 600 was not physically present.
h) P&ID R1.2 indicated a capped pipe section containing valve DE-04 600 joining the 0.75 inch HTRL pipe line between valves DE-04 100 and DE-04 101 within the piping associated with evaporator DE 04. The capped pipe section containing valve DE-04 600 was not physically present.
i) P&ID R1.3 indicated a capped pipe section containing valve FE-04 600 joining the 0.75 inch LTRL pipe line between valves FE-04 100 and FE-04 101 within the piping associated with evaporator FE 04. The capped pipe section containing valve FE-04 600 was not physically present.
j) P&ID R1.1 indicated the 4 inch CD pipe section containing valve EC-01 101, the 4inch CD pipe section containing EC-01 100, the 4 inch CD pipe section containing valve EC-02 101, and the 4 inch CD pipe section containing valve EC-02 100 all join the 4 inch CD pipe line containing the Tie-In For Future EC-3 through T-section junctions. The 4 inch CD pipe line containing the Tie-In For Future EC-3 actually joins a forked pipe section containing valves EC-01 100 and EC-01 101 for Evaporative Condenser EC-01, and a forked pipe section containing valves EC-102 100 and EC-02 101 for Evaporative Condenser EC-02.
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 4a
Type of Violation: Serious; $3,000
29 CFR 1910.119(e)(5): The employer did not document what actions were to be taken to resolve Process Hazard Analysis (PHA) recommendations:
a) The Recommendation Tracking Sheet for the 2012 PHA recommendation number 60 did not document what actions were taken to resolve recommendations when it was identified as fully implemented onApril 14, 2014.
b) The Recommendation Tracking Sheet for the 2012 PHA recommendation number 81 did not document what actions were taken to resolve or if actions were taken to address the recommendation.
c) The Recommendation Tracking Sheet for the 2012 PHA recommendation number 88 did not document what actions were taken to resolve recommendations when it was identified as fully implemented on April 15, 2014.
Citation 1 Item 4b
Type of Violation: Serious; GROUPED
29 CFR 1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected:
a) The employer received the 2014 PSM Audit Report on January 9, 2015. When reviewed by OSHA on January 6, 2016, the 2014 PSM Audit Recommendation Tracking Sheets 92, 93, 98, 99, 100, 101, 105 116 and 117 did not contain information describing the recommended action(s) the employer was planning to take, a schedule of recommended action(s) the employer was planning to take or if the recommended action(s) were completed.
Citation 1 Item 5
Type of Violation: Serious; $5,000
29 CFR 1910.119(f)(1)(iii)(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 that addressed health and safety considerations, such as precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment:
a) The employer has not developed clear instructions describing when an ammonia release constitutes an emergency and outside entities are needed to safely mitigate the ammonia release.
b) The employer has not developed clear instructions describing when an ammonia leak/release situation has deteriorated to a point that an employees’ experience, training and personal protective equipment no longer provides adequate protection.
c) The employer did not include the methods and equipment to be utilized to reach elevated ammonia refrigeration equipment needing maintenance or servicing in the operating procedures. d) The employer did not develop and implemented written procedures to maintain the Manning Systems Inc. Portable Gas Detection unit for ammonia in an operational and calibrated condition.
Citation 1 Item 6
Type of Violation: Serious; $5,000
29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment:
a) The employer had not developed and implemented written procedures for the inspections, testing and servicing needed to maintain the on-going integrity for the facility’s ammonia refrigeration system ammonia pumps.
b) The employer had not developed and implemented written procedures for the inspections, testing and servicing needed to maintain the on-going integrity for the facility’s ammonia refrigeration system Hansen Auto Purger.
Citation 1 Item 7
Type of Violation: Serious; $5,000
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:
a) The employer was not able to produce documentation that the mechanical integrity program weekly, monthly, tri-monthly, every three (3) months, and bi-annually tests and inspections for the compressors were conducted in 2015 and what the results were.
b) The employer was not able to produce documentation that the mechanical integrity program monthly and bi-annually tests and inspections for the evaporative condensers were conducted in 2015 and what the results were.
c) The employer was not able to produce documentation that the mechanical integrity program monthly and bi-annually tests and inspections for the evaporators were conducted in 2015 and what the results were.
Citation 1 Item 8
Type of Violation: Serious; $5,000
29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information on paragraph (d) of this section) before use:
a) The ice on the 0.5 inch pipe lines coming off the LTRS liquid pumps was identified as adding a dangerous amount of weight to the piping during B-109 inspections conducted on September 17, 2015. On January 14, 2016, OSHA observed a substantial ice buildup on the piping around the LTRS liquid pumps pipe lines.
b) The LTRS pressure vessel, liquid pumps and associated piping were identified having bad insulation during the B-109 inspections on September 17, 2015. On January 14, 2016, OSHA observed a substantial ice buildup on the LTRS liquid pumps, nearby equipment and pipe lines. Ice buildup is one indicator for faulty insulation.
c) The 4 inch CD pipe line between the HPR pressure vessel and the evaporative condensers was identified during the B-109 inspections as have bad rust blisters and needing replacement on October 27, 2015. On January 14, 2016, OSHA observed rust blisters the 4 inch CD pipe line.
d) The Evaporative Condenser EC-02 tubes were identified as being very rusty and soft during the B-109 inspection on September 10, 2015 and October 28, 2015. No documentation was available indicating the Evaporative Condenser EC-02 tubes had been repaired or removed from service during the January 2016 OSHA inspection.
Citation 1 Item 9
Type of Violation: Serious; $5,000
29 CFR 1910.147(c)(6)(i): The employer did not conduct an annual or more frequent inspection of the energy control procedure to ensure that the procedure and requirements of this standard were followed:
a) The employer did not perform energy control audits in 2015.
Citation 2 Item 1
Type of Violation: Other-than-Serious; $0.00
29 CFR 1910.119(d)(2)(i)(C): Process safety information pertaining to the technology of the process did not include the maximum intended quantity:
a) The employer has different maximum intended quantities for ammonia listed in different documents. The 2014 PSM Audit Report lists 15,725 pounds for the maximum intended inventory. The Risk Management Off Site Plan Update states the Maximum Quantity is 16,675 pounds and the Wisconsin 2014 Emergency and Hazardous Chemical Inventory Report also states the Maximum Daily Amount and Average Dairy Amount is 16,675 pounds.
Citation 2 Item 2
Type of Violation: Other-than-Serious; $0.00
29 CFR 1910.1200(e)(1): The employer did not develop, implement, and/or maintain at the workplace a written hazard communication program which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met:
a) The employer’s written hazard communication program, provided to OSHA on January 7, 2016, does not describe how employees will be given hazard communication training, the in-house labeling system and how/where the material safety data sheets/safety data sheets will be kept. Chemicals employees working at the facility may be exposed to include, but are not limited to, ammonia during an ammonia refrigeration system release, chemicals used during maintenance activities, and carbon monoxide from fuel powered industrial vehicles.
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