July 7, 2016 UPDATE – Company is Contesting all citations
OSHA has issued nine serious safety violations to a food industry provider of cold storage warehousing and logistical services. A January 2016 complaint investigation found the company violated OSHA’s process safety management procedures for using ammonia in its refrigeration warehouse facility. An investigation by the agency’s Kansas City area office found the company failed to:
Citation 1 Item 1
Type of Violation: Serious; $7,000
OSH ACT of 1970 Section (5)(a)(1): 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: 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 ammonia inhalation and fire/explosion hazards when the employer did not identify ammonia refrigeration piping by name and direction of flow in Engine Rooms 1, 2, and 3.
One acceptable means of abatement of this hazardous condition is to label or mark ammonia refrigeration piping as shown in IIAR bulletin 114 (March 2014) “Identification of Ammonia Refrigeration Piping and System Components”, Section 4.1 “Piping Markers”, and Section 5.0 (a-d) “Marker Location”.
Citation 1 Item 2
Type of Violation: Serious; $7,000
29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP’s). On or about January 20, 2016, the employer did not document that is complied with recognized and generally accepted good engineering practices (RAGAGEP) exposing employees to the hazards of inhalation of toxic ammonia and/or fire/explosion in the following instances, see A through E:
A. The employer failed to document compliance with RAGAGEP, such as IIAR Bulletin 114 “Identification of Ammonia Refrigeration Piping and System Components” Section 4.1 “Piping Markers” and Section 5.0 (a-d) “Marker Location”, March 2014, as the employer failed to mark and/or label ammonia refrigeration equipment, including:
1. Engine Room 5, Evaporating Condenser, tower EC-1
2. Engine Room 6, Evaporating Condenser, tower EC-2
3. Engine Room 7, Evaporating Condenser, towers EC-1 and EC-2
4. Engine Room 8, Evaporating Condenser, towers EC-1, EC-2 and EC-3
5. Engine Room 11, Evaporating Condenser, tower EC-1, EC-2 and EC-3
B. Failure to document compliance with RAGAGEP, such as HAR Bulletin 110 “Guidelines for: Startup, Inspection and Maintenance of Ammonia Mechanical Refrigerating Systems” Section 6.6 Valves and Sensing Devices Subsection 6.6.1 Shut-off Valves, as the employer failed to change out ammonia refrigeration system safety relief valves prior to their 5 year due dates from the date of installation, including:
1. Engine Room 6, Heat Exchangers 1, 2 and 3.
These are dual relief systems using Hansen Valves.
Relief Valve – HE2 (#5), manufactured by Hansen was not changed at or before date. Some of the valves due date are July, November and December 2015.
C. The employer failed to document compliance with RAGAGEP, such as ASHARAE 15-2013, Section 9.4.3.1 and 9.4.3.2 as the employer failed to provide hydrostatic relief for a section of piping in the Engine Room 8 thermos-syphon return line that could trap liquid ammonia between valves leading to an overpressure scenario and rupture the piping resulting in a release of ammonia.
D. The employer failed to document compliance with RAGAGEP, such as ASHARAE-15-2013, Section 8.11.4, as the employer failed to safely install ventilation fans in that the inlets of two ventilations fans are located in the north wall and a small fan located near the inlet louver south wall allowing for exhausted ammonia vapors to be drawn back into Engine Room 8.
E. The employer failed to document compliance with RAGAGEP, such as ASHARAE 15-2013 Safety Standard for Refrigeration Systems, Section 9.7.8 as the employer failed to locate discharges from safety relief valves (SRV) in safe locations in that the header relief system for Engine Room 8 had an SRV that was located adjacent to Condenser # 2 such that it would discharge to a ladder and catwalk area that is used by employees.
Citation 1 Item 3
Type of Violation: Serious; $7,000
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:
The employer is failing to protect employees by allowing the build up of ice and rust on the equipment.
A. Valves cannot be utilized due to ice build-up. An evaluation for ice build-up should be made in all locations for the remediation.
(1) Vessel Room 86/87
i. Heat Exchanger 2, Valves 12, 23 and 24
ii. Heat Exchanger 3, Valves 21, 22 and 23
(2) Engine Room 8
i. Vessel 5. Valve 07
ii. Vessel 2
B. An evaluation for corrosion had not been performed in all locations for the remediation. The rust issues on multiple Sections of pipe for the covered process as shown in the following instances:
(1) Vessel Room 86/87
i. pipes
ii. Heat Exchanger 4
(2) Engine Room 6
i. Heat Exchanger 2, Valve 3
(3) Engine Room 8
i. Vessel 2, pipe
C. Ventilation fan is not functioning as designed in Vessel Room 86/87. It shuts off after approximately 5 minutes of continuous use which may not allow for the correct ventilation rates for the room as outlined through the ventilation calculation for that location.
D. Valves at the following locations were not maintained in a manner consistent with the design specifications, manufacturer’s instruction and as outlined in IIAR bulletin 110 Guidelines for Start-up, Inspection and Maintenance of Ammonia Mechanical Refrigeration Systems Section 6.6.1 Shut-off Valves
1. Engine Room 4, Compressor #1, Oil Fill Valve – The valve stem is damaged and will not turn.
2. Engine Room 11, Compressor# 1, Discharge Valve
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; $7,000
29 CFR 1910.119(l)(2)(ii): The management of change procedures did not assure that the impact of changes on safety and health were addressed prior to any change.
(a) The employer is failing to ensure that the management of change procedures for a recent Header Relief Project in Engine Room 8 included a review of the impact on safety and health.
29 CFR 1910.119(l)(2)(ii): The management of change procedures did not assure that the impact of changes on safety and health were addressed prior to any change. (a) The employer is failing to ensure that the management of change procedures for a recent Header Relief Project in Engine Room 8 included a review of the impact on safety and health.
29 CFR 1910.119(l)(2)(ii): The management of change procedures did not assure that the impact of changes on safety and health were addressed prior to any change. (a) The employer is failing to ensure that the management of change procedures for a recent Header Relief Project in Engine Room 8 included a review of the impact on safety and health.
The company decided not to accomplish a Process Hazard Analysis for the upgraded system. As a result an issue was created where hydrostatic pressure could accumulate if the valves for the Thermo-syphon sending line and Thermo-syphon return lines for each compressor were closed. The line had a safety relief valve which was removed as part of the project creating this issue.
Citation 1 Item 4b
Type of Violation: Serious; Grouped
29 CFR 1910.119(l)(3): The employer did not train employees in the changes to a covered process prior to start up. The employer is failing to train their employees on the issues of hydrostatic pressure build-up of the thermos-syphon sending valves, thermo-syphon return valves, and the hazards of closing both valves simultaneously.
Citation 1 Item 4c
Type of Violation: Serious; Grouped
29 CFR 1910.119(l)(5): When a change covered by this paragraph resulted in a change in the operating procedures or practices required by paragraph (f) of this section, such procedures or practices were not updated accordingly.
The employer is failing to change the operating procedure when changes to the system are made which render the operation procedure obsolete or incorrect. This was most recently documented where there was not a Standard Operating Procedure for the recent changes in thermo-syphon relief system.
Citation 1 Item 5
Type of Violation: Serious; $7,000
29 CFR 1910.146(k)(2)(ii): Affected employees were not trained to perform assigned rescue duties.
The employer did not ensure that such employees had successfully completed the training required to establish proficiency as an authorized entrant, as provided by paragraphs (g) and (h) of this section:
The employer is failing to conduct rescue training for confined space entry. This was most recently documented where employees are exposed to confined space hazards and no training has been provided for rescue duties.
Citation 1 Item 6
Type of Violation: Serious; $4,400
29 CFR 1910.303(b)(l)(ii): Electrical equipment was not free from recognized hazards, based on the mechanical strength and durability, including, for parts designed to enclose and protect other equipment, the adequacy of the protection thus provided:
The employer is failing to protect employees from electrical shock hazards. Electrical conductors were exposed inside metal conduit which were pulled away from a junction box in locations listed, but not limited to:
1. Vessel Room 86/87 2. Engine Room 5
Citation 1 Item 7
Type of Violation: Serious; $4,400
29 CFR 1910.305(b)(1)(ii): Unused openings in boxes, cabinets, or fittings were not effectively closed:
In Engine Room #8: The employer is failing to protect employees from hazards due to an unused opening in a junction box.
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 8a
Citation 1 Item 8a
Type of Violation: Serious; $6,600
29 CFR 1910.305(e)(1): Cabinets, cutout boxes, fittings, boxes, and panel board enclosures in damp or wet locations were not installed to prevent moisture or water from entering and accumulating within the enclosures: The employer is failing to protected employees from electrical shock hazards.
This was most recently documented in Vessel Room 86/77, where employees are expose to electrical components that are not approved for wet or damp locations.
Citation 1 Item 8b
Type ofViolation: Serious; Grouped
29 CFR 1910.334(a)(4): Portable electric equipment and flexible cords that was used in highly conductive work locations (such as those inundated with water or other conductive locations) or in job locations where employees were likely to contact water or conductive liquids were not approved for those locations:
The employer is failing to protect employees from electrical shock hazards. A 480 volt heater unit is being used to assist with thawing ice build-up on the chiller units located in the freezer. The location varies dependent upon where the ice has accumulated. The heater is not approved for locations (not identified as such on the ID plate or labeling). This unit is also being directly wired into the power supply for the chiller fan system (480 volts) due to there not being any type of male plug on the cord.
Citation 1 Item 9
Type of Violation: Serious; $4,400
29 CFR 1910.1200(h)(3)(iii): Employee training did not include the measures employees can take to protect themselves from chemical hazards, including specific procedures the employer had implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures and personal protective equipment to be used:
The employer is failing to protect employees from the hazards associated with hazardous chemical exposure. General hazard communication overview training is provided; however, it is not specific to the chemicals to which the employees are commonly exposed.
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