A Cincinnati foods plant has agreed to correct repeated deficiencies in its risk management plan as part of a settlement with Ohio EPA. The company cooks, packages and sells chicken parts. The facility keeps approximately 46,000 pounds of anhydrous ammonia onsite to be used in the refrigeration process. A 2004 Ohio EPA inspection found 10 rule violations. No penalty was assessed but the company was required to correct the violations and bring the facility into compliance. All of the violations were corrected. However, on November 30, 2010, Ohio EPA conducted a second five-year audit and found nine rule violations, six of which were present at the first inspection. Some of the violations included failure to:
- maintain records for the worst-case and alternative scenarios;
- conduct a process hazard analysis every five years and complete recommendations from analyses done in 2005 and 2010;
- provide training every three years to ensure operators understand and adhere to current operations and determine that employees understand the training;
- create and implement a mechanical integrity program;
- determine and document appropriate responses to each of the findings in the 2008 compliance audit;
- develop and implement an employee participation program; and
- revise, update and submit the risk management plan within five years of its last update.