OSHA has cited a discount retailer with 19 serious safety and health violations at the company’s distribution center that are related to process safety management, including exposing workers to anhydrous ammonia while storing frozen products in refrigeration units. OSHA’s inspection was initiated as part of the agency’s national emphasis program on process safety management for covered chemical facilities. Proposed penalties total $121,000. The violations include failing to compile process safety information for instruments used as safeguards, ensure that equipment complies with recognized and good engineering practices, inspect and test equipment identified as safeguards, complete a process safety management compliance audit, develop and implement an emergency action plan, and provide guarding on elevated platforms above 4 feet. Here is a breakdown of the citations…
Process Safety Information
- no relief system design or design basis (Serious; $5K)
- no ventilation design data (Serious; $5K)
Operating Procedures
- the following Safety Systems and their functions were not listed in the SOPs (Serious; $7K)
- NH3 Detectors
- Emergency Ventilation System triggered by the NH3 detectors
- High and Low pressure cutouts on compressors
- High Discharge Temperature cutouts
- Low Suction pressure cutouts
- Low Oil Pressure cutouts
- no LOTO procedures for the compressors (Serious; $7K)
- also cited for 1910.147(c)(4)(i) but no $ cited
- no LOTO for refrigeration techs (Serious; $5K)
Training
- train records did not include the identity of the employee, the date of training, and the means used to verify that the employee understood the training (Serious; $5K)
Pre-Startup Safety Review
- No PSSR conducted on a new condenser (Serious; $7K)
Mechanical Integrity
- No written MI procedures for: (Serious; $7K)
- External visual inspections of insulated vessels
- External visual inspections of insulated piping segments
- External visual inspections of un-insulated piping segments
- Inspection, Testing and Preventive maintenance on compressors
- Establishing Thickness Monitoring Locations (TMLs) on piping
- Inspections and testing did not follow RAGAGEP – IIAR Bulletin 110 in that nine (9) process vessels had no NDE/NDT data (Serious; $7K)
- Receiver
- Liquid Transfer/Dump Tank
- Low Stage Accumulator 1
- High Stage Accumulator 1
- High Stage Accumulator 2
- Low Stage Accumulator 1 Oil Pot
- Heat Exchanger for Banana Rooms
- Two (2) Heat Exchnagers for under floor heat
- Inspection/Testing on safety systems was not in accordance with manufacturer’s recommendations or RAGAGEP IIAR Bulletin 110 (Serious; $7K)
- PLEASE NOTE that OSHA used the safety systems identified as safeguards in the 2010 PHA for this citation!!!!!
- Annual High Pressure Cutouts on four (4) compressors
- Annual E-Stop Button (1 located outside engine room)
- Annual Low Oil Pressure Cutouts on four compressors
- Annual High Oil Temperature Cutouts on four compressors
- Annual High Level Alarms on three (3) vessels
- Annual High Discharge Temperature cutouts on four compressors
- Annual Low Suction Pressure Cutouts on four compressors
- Annual High level Shutoffs on three (3) vessels
- Annual visual inspections of vessels and piping as shown on P&ID R-2
- Documentation of inspections and tests conducted did not include a description of the inspection/test or the results of the inspection/tests on the following equipment: (Serious; $7K)
- High Pressure Cutouts on four (4) compressors
- E-Stop Button (1 located outside engine room)
- Low Oil Pressure Cutouts on four compressors
- High Oil Temperature Cutouts on four compressors
- High Level Alarms on three (3) vessels
- High Discharge Temperature cutouts on four compressors
- Low Suction Pressure Cutouts on four compressors
- High level Shutoffs on three (3) vessels
- Did not address deficiencies outside acceptable limits in a timely fashion (Serious; $7K)
- Ventialtion intake louver controls were disconnected and inoperable
Management of Change
- MOCs not done on three (3) changes (Serious; $7K)
- Addition of NH3 to process when the maximum intended inventory was increased for additional cooling capacity
- Removal of two (2) condensers
- Installation of an additional condenser
Emergency Planning and Response
- No Emergency Action Plan (EAP) for the entire facility per 1910.38 (Serious; $7K)
Audits
- not doing PSM audits every three years (Serious; $7K)
Items cited using other OSHA standards
- Open sided platform above the engine room not protected with standard railing and toeboards (Serious; $5K)
- No certified PPE Hazard Assessments for exposure to NH3, Premium 2-Stage Hydrocracked Compressor Fluids, propylene glycol, and extreme cold temperatures (Serious; $5K)
- Did not ensure employees use appropriate Eye and Face protection when exposed to NH3, Premium 2-Stage Hydrocracked Compressor Fluids, propylene glycol
- Did not ensure employees use appropriate hand protection (gloves) when exposed NH3, Premium 2-Stage Hydrocraked Compressor Fluids, propylene glycol
- No written respiratory protection program (Serious; $7K)
- Refrigeration techs wore full face APR when draining oil and responding to leaks
- Containers of drained refrigeration oil were not labeled
No written HAZCOM program (Serious; $7K)