OSHA has cited a pasta manufacturing plant with 12 safety and PSM violations following a complaint inspection alleging workers were exposed to ammonia hazards in July 2012 at the plant, which was being retrofitted for use as a pasta production facility. Proposed fines total $54,000. Eight serious violations of OSHA’s PSM standard were cited for deficiencies in the company’s ammonia refrigeration process. These included a lack of written standard operating procedures for the ammonia refrigeration process; no emergency action plan; failing to perform inspections and tests on process equipment; not addressing the hazards of the ammonia refrigeration process; and failing to address the findings and recommendations of the process hazard analysis team. Three additional serious violations involve failing to develop, implement and train employees in hazard communication, provide an emergency eyewash station and provide material data safety sheets for hazardous chemicals present in the workplace. Additionally, one other-than-serious violation was issued for a slip and trip hazard after water was found on the floor of the engine room. Here is a breakdown of the citations:
Compressed Gas Cylinders
- 1910.101(b) – 32 compressed gas cylinders in use, located in the production department next to the pasta packaging line were not supported to prevent them from being knocked over. (Serious; $4K)
Process Safety
- 1910.119(c)(1) – no written plan of action regarding the implementation of an employee participation program. PHA done without input from employees who operate, maintains, and monitors the refrigeration process. (Serious; $5K)
- 1910.119(d)(3)(i)(G) – no material and energy balances for the process which was built after May 26, 1992 (Serious; $5K)
Process Hazard Analysis
- 1910.119(e)(3)(i) – PHA did not address hazards of the refrigeration process that were not controlled as prescribed by ASHRAE 15 or equivalent standard. Hazards included, but not limited to, (Serious; $5K)
- absence of visual and audible ammonia alarms inside and outside engine rooms, with manual resets located inside the engine rooms and with the meaning of each alarm clearly marked by signage near the annunciator.
- absence of legible permanent signs, securely attached and easily accessible, reading “Engine Room – Authorized Personnel Only” and further communicating that entry is forbidden except by those personnel trained in emergency procedures when the ammonia alarm has been activated.
- Doors communicating with the engine rooms were not tight fitting, permitting passage of escaping ammonia to other work areas of the building.
- Piping piercing the interior walls of the engine room were not tightly sealed to the walls permitting passage of escaping ammonia to other work areas.
- Emergency shutdown procedures including precautions to be observed in case of a breakdown or leak, were not posted outside each engine room, immediately adjacent to each door.
- Ammonia sensors were mounted on high ceilings of the engine room, may not be able to detect releases of ammonia that form dense mixtures of ammonium hydroxide which tend to travel along the ground rather than rise rapidly.
Operating Procedures
- 1910.119(f)(1) – no written operating procedures that provided clear instruction for safely conducting activities in each covered process consistent with the PSI and which addressed the elements listed in (f)(1)(i) through (f)(1)(iv):
- no written procedures for each operating phase of the process. There were no written SOPs for refrigeration equipment which included evaporators, condensers, pressure vessels, and associated pumps and oil pots that detailed the procedures for normal operations, normal shutdown, temporary operations; emergency operations, normal shutdown and safety and health consideration for start-up after a turnaround. Additionally, there were no written SOPs for emptying the oil pot. (Serious; $5K)
Contractors
- 1910.119(h)(2)(iii) – did not explain to contractor employers from XXXXXXXX operating the ammonia refrigeration system, the applicable provisions of the emergency action plan. (Serious; $5K)
Pre-Start Up Safety Review
- no PHA for new facilities and recommendations resolved or implemented prior to the introduction of over 10,000 pounds of NH3 go the refrigeration system which occurred on 8/18/12. The following recommendations were not implemented prior to 8/18/12: (Serious; $5K)
- consider using the NH3 detectors in the plant to activate a cut-off of the ammonia liquid supply to that area
- ensure that a complainant emergency response plan is in place prior to employees beginning work
- ensure that a compliant employee orientation plan is in place prior to employees beginning work
- ensure that the planned NH3 detectors are actually installed
- ensure that the planned eye wash and shower station are actually installed
- ensure that the contractor qualification program is in place and that all contractors are qualified to work in compressor room
- ensure that forklift and manlift operators are properly trained and qualified
- ensure that operator/mechanics who operate the NH3 system are properly trained and qualified, whether these are in-house operators or outside contractors.
- ensure a compliant LOTO procedures is in place and used by both in house mechanics and outside contractors
- coordinate with local fire department and the LEPC for response to emergencies
- ensure the MI/PM program is implemented and documented
- ensure that a compliant Hot Work Procedure is in place for both in house mechanics and outside contractors
- ensure a compliant confined space entry program is in place and used by both in house mechanics and outside contractors
- ensure that contractors are given orientation about the plant and procedure including roof egress points
- ensure that the operator/mechanics either in-house or outside contractors are trained in the SOPs prior to operating equipment
- consider annual vibration testing for compressor to maintain their integrity over time
- consider havign an NH3 detector in the RV piping header to alert personnel to leaking RVs
- ensure the coalescing filter is on a regular manufacturer recommended PM
- consider having a periodic oil analysis to monitor compressor condition
- ensure there is an annual PM on the high level cutouts on the recirculator
- consider having a night time security include a walkthrough of the compressor room
- consider locking out and tagging the drain on the HPR
- consider locking out and tagging out the drain valve on the sight glass column
NOTE from SAFTENG: using a lockout lock and tag for these purpose would actually be a violation of 1910.147(c)(5)(ii). Lockout/Tagout devices are to be used ONLY for LOTO during servicing and maintenance. Instead of placing a LOTO device on these valves, a “Car Seal”program should be established. SAFTENG Members can learn more HERE.
- ensure that low temp piping is either rated for the temperatures used or stress tested and certified
- ensure a check valve is installed and functional in the NH3 charging line
- esnure that a compliant SOP for NH3 charging is implemented and used
- ensure that NH3 charging line on the HPR is properly guarded from traffic.
Mechanical Integrity
- 1910.119(j)(4)(i) – inspections and tests were not performed on the NH3 refrigeration process equipment to maintain its mechanical integrity. There were no inspections and tests conducted on evaporators, consdensers, pressure vessels and associated pumps and oil pots. (Serious; $5K)
- 1910.119(j)(4)(iv) – did not document each inspection and test that has been performed on process equipment on NH3 refrigeration components such as evaporators, condensers, pressure vessels and associated pumps, oil pots and compressors. Documentation did not identify the date of the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test. (Serious; $0)
Emergency Response
- 1910.119(n) – No emergency action plan established and implemented (Serious; $5K)
Emergency Eyewash/Shower
- 1910.151(c) – employees exposed to injurious corrosive material were not provided suitable quick drenching or flushing facilities of the eyes were not within the work area for immediate emergency use. The ammonia refrigeration engine room did not have a pedestal mounted eyewash and shower station installed.
- employees in the waste water treatment department exposed to 50% sodium hydroxide (pH 14) and sulfuric acid (pH 11) (Serious; $5K)
HAZCOM
- 1910.1200(e) – no written HAZCOM program that describes at least the following: (Serious; $5K)
- labeling of containers or hazardous chemicals
- MSDS availability
- training
- complete list of hazardous chemicals
- methods to inform employee of hazards of non-routine tasks
- methods to inform other employees of MSDS availability, the labeling systems and any precautionary measures to protect employees
- 1910.1200(e)(1)(i) – written hazcom program did not include a list of hazardous chemicals known to be present using an identity that was referenced on the appropriate MSDS (Serious; $0)
- 1910.1200(g)(1) – no MSDS for Anhydrous Ammonia, Sulfuric Acid, Liquid Caustic Soda. (Serious; $0)
- 1910.1200(h)(1) – employees not trained on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard was introduced in their work area. (Serious; $0)
Walking/Working Surfaces
- 1910.22(a)(2) – in the engine room, next to eyewash station, across from compressor 110, a constant stream of water was allowed to flow across the main aisle way, to the drain approximately two feet away. (Other-than-Serious; $0)
CLICK HERE (pdf) for the citations.