This case reflects a common issue in ammonia refrigeration: Lack of or Poor Lockout/Tagout Practices.
This 1,600-pound release was caused by an existing ammonia compressor that was started up on an ammonia line that was meant to be “TAGGED OUT” of service (however, the tag had fallen off) while in the process of tying the existing system into new expansion equipment.
EPA inspectors are not usually LOTO SMEs, and as such, they probably do not know the “Tag-Plus” requirements when using “tagout” vs. “lockout.” However, saying there is a small problem with LOTO in the ammonia refrigeration sector is an understatement. Simply closing a valve and hanging a DANGER Do NOT Operate tag on the valve handle is NOT “tagout,” nor does it come close to the “Tag-Plus” requirements of 1910.147(c)(3)(i), which requires the tagout program will provide a level of safety equivalent to that obtained by using a lockout program.
| 1910.147(c)(3)(i) When a tagout device is used on an energy isolating device which is capable of being locked out, the tagout device shall be attached at the same location that the lockout device would have been attached, and the employer shall demonstrate that the tagout program will provide a level of safety equivalent to that obtained by using a lockout program. |
As a reminder for those who utilize “tagout,” attaching the tags to the energy isolation device(s) must meet some specific requirements. Namely, the means of attachment MUST be:
- non-reusable,
- attachable by hand,
- self-locking,
- non-releasable with a minimum unlocking strength of no less than 50 pounds, and
- environment-tolerant
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1910.147(c)(5)(ii)(C)(2) Tagout devices Tagout devices, including and their means of attachment, shall be substantial enough to prevent inadvertent or accidental removal. Tagout device attachment means shall be of a non-reusable type, attachable by hand, self-locking, and non-releasable with a minimum unlocking strength of no less than 50 pounds and having the general design and basic characteristics of being at least equivalent to a one-piece, all-environment-tolerant nylon cable tie. |
Lastly, the old “red rag” program or the more modern-day “timber cruising ribbon” is NOT even close to meeting OSHA’s minimum expectations regarding LOTO.
The respondent is the owner and operator of a chicken processing plant. On July 1, 2023, there was an incident at the Facility that resulted in an accidental release of 1,600 pounds of anhydrous ammonia and an exposure to three employees. Pursuant to Section 114 of the CAA, 42 U.S.C. § 7414, the EPA requested documentation on February 14, 2024, and Respondent provided on March 5, 2024, information concerning the Incident and Respondent’s compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68 (the “Investigation”).
The Respondent’s facility is a chicken further processing plant. Respondent’s facility specializes in processing and packaging chicken, operating three production lines, and producing approximately 110 million pounds of fully cooked chicken products annually. Processing aid substances handled and stored onsite consist of ammonia and sanitation chemicals. The Respondent’s processes meet the definition of “process” and “covered process,” as defined by 40 C.F.R. § 68.3. The Respondent’s RMP Program Level 3 covered process stores or otherwise uses a regulated substance in an amount exceeding the applicable threshold.
Respondent has at times maintained greater than a threshold quantity of anhydrous ammonia in a process at the Facility, meeting the definition of “covered process” as defined by 40 C.F.R. § 68.3.
EPA Findings of Violation: