NH3 2,100 pound NH3 LOPC event exposes eight (8) workers, one hospitalized ($119K)

On January 27, 2019, 12 employees needed transport to nearby hospitals after a a release of 2,100 pounds of anhydrous ammonia.  OSHA cited the facility for failing to:

  • Equip an ammonia refrigeration system with a pressure relief device as referenced by the manufacturer’s operating manual;
  • Train technicians to use an alternative over-pressure safety procedure to prevent pipes from rupturing and releasing anhydrous ammonia;
  • Perform a management of change procedure to determine the effects of removing safety relief devices from all condensers;
  • Make available medical surveillance for response team members exposed to hazardous substances above the permissible exposure limits;
  • Inspect Level B respiratory protection equipment; and
  • Provide a medical evaluation to determine each employee’s ability to use a respirator.

Violation Summary
  Serious Willful Repeat Other Total
Initial Violations 10     3 13
Current Violations 10     3 13
Initial Penalty $117,446 $0 $0 $1,895 $119,341
Current Penalty $117,446 $0 $0 $1,895 $119,341
FTA Amount $0 $0 $0 $0 $0

 

Violation Items
# ID Type Standard Issuance Abate Curr$ Init$ Contest
1. 01001 Serious

19100029 B02 I – Midrails are installed at a height midway

between the top edge of the guardrail system and the

walking-working surface;

07/25/2019 08/02/2019 $9,472 $9,472 08/20/2019
2. 01002 Serious

19100119 D03 II – The employer shall document that equipment

\complies with recognized and generally accepted good engineering

practices.

07/25/2019 08/02/2019 $13,260 $13,260 08/20/2019
3. 01003 Serious

19100119 J03 – The employer shall train each employee involved

in maintaining the on-going integrity of process equipment in an

overview of that process and its hazards and in the procedures

applicable to the employee’s job tasks to assure that the employee

can perform the job tasks in a safe manner.

07/25/2019 08/16/2019 $13,260 $13,260 08/20/2019
4. 01004 Serious

19100119 J04 III – The frequency of inspections and tests of process

equipment shall be consistent with applicable manufacturers’

recommendations and good engineering practices, and more

frequently if determined to be necessary by prior operating experience.

07/25/2019 08/16/2019 $13,260 $13,260 08/20/2019
5. 01005 Serious

19100119 L01 – The employer shall establish and implement written

procedures to manage changes (except for “replacements in kind”)

to process chemicals, technology, equipment, and procedures; and,

changes to facilities that affect a covered process.

07/25/2019 08/16/2019 $13,260 $13,260 08/20/2019
6. 01006 Serious

19100119 N – The employer shall establish and implement an emergency

action plan for the entire plant in accordance with the provisions of

29 CFR 1910.38. In addition, the emergency action plan shall include

procedures for handling small releases. Employers covered under this

standard may also be subject to the hazardous waste and emergency

response provisions contained in 29 CFR 1910.120 (a), (p) and (q).

07/25/2019 08/16/2019 $13,260 $13,260 08/20/2019
7. 01007 Serious

19100120 F03 I B – At least once every twelve months for each

employee covered unless the attending physician believes a

longer interval (not greater than biennially) is appropriate;

07/25/2019 08/16/2019 $13,260 $13,260 08/20/2019
8. 01008 Serious

19100134 G01 I A – Facial hair that comes between the sealing

surface of the facepiece and the face or that interferes with valve

function; or

07/25/2019 08/02/2019 $7,577 $7,577 08/20/2019
9. 01009 Serious 19100134 H02 II A – Kept accessible to the work area; 07/25/2019 08/02/2019 $13,260 $13,260 08/20/2019
10. 01010 Serious

19101200 E01 – Employers shall develop, implement, and maintain

at each workplace, a written hazard communication program which

at least describes how the criteria specified in paragraphs (f), (g),

and (h) of this section for labels and other forms of warning, safety

data sheets, and employee information and training will be met,

and which also includes the following:

07/25/2019 08/16/2019 $7,577 $7,577 08/20/2019
11. 02001 Other 19040007 B05 – recordkeeping 07/25/2019 08/02/2019 $1,895 $1,895 08/20/2019
12. 02002 Other

19100120 G05 VIII – PPE inspection procedures prior to, during, and

after use,

07/25/2019 08/16/2019 $0 $0 08/20/2019
13. 02003 Other

19100134 E01 – The employer shall provide a medical evaluation to

determine the employee’s ability to use a respirator, before the employee

is fit tested or required to use the respirator in the workplace. The employer

may discontinue an employee’s medical evaluations when the employee

is no longer required to use a respirator.

07/25/2019 08/16/2019 $0 $0 08/20/2019
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