OSHA has cited a food facility after a worker required medical treatment due to an anhydrous ammonia leak in the packaging house. OSHA found issues with the Emergency Action Plan and Employee Alarm System, RAGAGEP compliance with IIAR standards, PSM Initial and Refresher Training, HAZCOM Training, PSM Incident Investigation Procedures, Lack of an Emergency Response Plan for responding to NH3 releases, lack of medical surveillance for responders, respirator medical evaluations, fit-testing issues, SCBA inspections, contractor safety evaluations, and lack of eyewash/safety shower.
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 1a
Type of Violation: Serious; $11,934
29 CFR 1910.38(d): The employer did not have and maintain an employee alarm system with a distinctive signal for each purpose so that it complied with the requirements of 1910.165:
On or about November 23, 2018, in the packing house, the employer did not have an employee alarm system to provide audible and visual warning for an ammonia release to enable the safe escape of all employees.
Citation 1 Item 1b
Type of Violation: Serious
29 CFR 1910.165(b)(2): The employee alarm could not be perceived above ambient noise or light levels by all employees in the affected portions of the workplace:
On or about November 23, 2018, in the maintenance department of packinghouse, the employer did not have an employee alarm that was activated and perceived by employees working in and around the area, when an ammonia leak occurred inside the engine room.
Citation 1 Item 1c
Type of Violation: Serious
29 CFR 1910.165(b)(5): Procedures were not established for sounding emergency alarms in the workplace
On or about November 23, 2018, in the packinghouse, the employer did not develop procedures for employees to activate employee alarms in order to notify and signal employees of an emergency situation that requires evacuation and emergency response.
Citation 1 Item 2
Type of Violation: Serious; $11,934
29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP)
(a) On or about November 23, 2018, the employer did not document that the engine room, where the ammonia refrigeration equipment was located in the packing house, complied with the employers chosen RAGAGEP, such as but not limited to, IIAR 2-2014, Standard for Safe Design of Closed Circuit Ammonia Refrigeration System (Section 6.10.4), which requires machinery room doors to be self-closing, tight-fitting. In addition, machinery room egress doors are required to be equipped with panic hardware and be side hinged to swing in the direction of egress.
(b) On or about November 23, 2018, the employer did not document that the engine room, where the ammonia refrigeration equipment was located in the packing house, complied with the employers chosen RAGAGEP, such as but not limited to, IIAR 2-2014, Standard for Safe Design of Closed Circuit Ammonia Refrigeration System (Section 6.14.5.1 ), which requires the machine room ventilation to maintain a negative pressure threshold while the ammonia system is operating to avoid migration of ammonia vapor to adjacent areas in the event of a leak. The employer failed to ensure negative pressure ventilation was maintained in the machinery room when a portion of the engine room wall was cut out in order to move two compressors out of the room.
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 3a
Type of Violation: Serious; $11,934
29 CFR 1910.119(g)(1)(i): Each employee involved in operating a process was not provided training which included an emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee’s job tasks:
On or about November 23, 2018, in the packinghouse, the employer did not provide specific safety and health training to employees who are involved in the operation of the ammonia refrigeration system by assisting with tasks such as. but not limited to, oil draining procedures and daily compressor checks.
Citation 1 Item 3b
Type of Violation: Serious
29 CFR 1910.1200(h)(1): Employees were not provided effective information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard that the employees had not been previously trained about was introduced into their work area:
On or about November 23, 2018, in the packinghouse, the employer did not provide effective training on the health hazards of ammonia to protect employees in the event of a spill or leak from a refrigeration system processing over 10,000 pounds of anhydrous ammonia.
Citation 1 Item 4
Type of Violation: Serious; $11,934
29 CFR 1910.119(m)(3): The incident investigation team did not consist of at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident:
On or about November 23, 2018, at the packinghouse, the employer did not include the main operator of the ammonia system where an ammonia release occurred resulting in employee exposure to ammonia vapors, in the incident investigation process.
Citation 1 Item 5
Type of Violation: Serious; $11,934
29 CFR 1910.120(q)(2): The employer did not develop an emergency response plan for emergencies which addressed the following minimum requirements of this standard: 1910.120(q)(2)(i) through 1910.120(q)(2)(xii):
(a) On or about November 23, 2018, at the packinghouse, the employer did not develop a written emergency response plan for employees assigned to respond to hazardous material emergencies, such as, but not limited to, ammonia release from the refrigeration system processing over 10,000 pounds of anhydrous ammonia.
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 6a
Type of Violation: Serious; $11,934
29 CFR 1910.120(q)(9)(i): Members of an organized and designated HAZMAT team and hazardous materials specialist did not receive a baseline physical examination and/or was not provided with medical surveillance as required in 29 CFR 1910.120(f):
(a) On or about November 23, 2018, at the packinghouse, the employer did not provide medical surveillance to all employees assigned to hazardous response team where they will respond to chemical emergencies, such as, but not limited to, an ammonia release from the refrigeration system.
Citation 1 Item 6b
Type of Violation: Serious
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:
On or about November 23, 2019, the packing house, the employer did not provide medical evaluations to employees who don tight-fitting full-face respirators to respond to ammonia releases.
Citation 1 Item 7
Type of Violation: Serious; $11,934
29 CFR 1910.134(f)(1): The employer did not ensure that employee(s) required to use a tight-fitting facepiece respirator passed the appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT):
On or about November 23, 2019, the packing house, the employer did not ensure an employee required to respond to ammonia release wearing a full face tight-fitting respirator was given a fit test.
Citation 1 Item 8
Type of Violation: Serious; $11,934
29 CFR 1910.134(h)(3)(i)(B): Respirators maintained for use in emergency situations were not inspected at least monthly and in accordance with manufacturer recommendations:
On or about November 23, 2018, at the packinghouse, the employer assigns employees to respond to chemical emergencies using SCBA equipment that were not inspected monthly.
Citation 2 Item 1
Type of Violation: Other-than-Serious; $0.00
29 CFR 1910.119(g)(2): Refresher training was not provided at least every three years to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process:
On or about November 23, 2018, in the engine room, the employer did not provide refresher training to employees who perform tasks in the operation of an ammonia refrigeration system processing over 10,000 pounds of ammonia.
Citation 2 Item 2
Type of Violation: Other-than-Serious; $0.00
29 CFR 1910.119(h)(2)(i): The employer, when selecting a contractor, did not obtain and evaluate information regarding the contract employer’s safety performance and program:
On or about November 23, 2018, in the engine room, the employer did not obtain the safety performance and safety programs for the contractor who was hired operate an ammonia refrigeration system that processes over 10,000 pounds of anhydrous ammonia.
Citation 2 Item 3
Type of Violation: Other-than-Serious; $0.00
29 CFR 1910.151(c): When the eyes or body of any person 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:
(a) On November 23, 2018, in the Engine room of the Packing House, the employer did not provide suitable facilities for quick drenching or flushing of the eyes in the immediate work area for emergency use for employees operating and maintaining an ammonia refrigeration system, a highly hazardous and corrosive chemical.
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