ATTENTION FOOD PROCESSOR CLIENTS: OSHA is onto the Clean-In-Place (CIP) process and how it contains “hazardous energy sources”, which in turn makes opening up the CIP system a “line-break” and LOTO activity. These citations center around PPE and LOTO issues at a food plant where workers were exposed to “hot water”.
OSHA has cited a food processor for amputation and other hazards after two employees were hospitalized in separate incidents and face $164,997 in penalties. On August 2, 2018, an employee suffered burns while using hot water under pressure. Six days later, another employee suffered an amputation to the tip of the finger. OSHA cited the company for exposing employees to amputation hazards; failing to implement lockout/tagout procedures to control hazardous energy and train employees on these procedures; failing to ensure employees isolated energy sources before conducting line-breaking work; not providing personal protective equipment, and failing to implement a bloodborne pathogen program.
Here is a breakdown of the citations:
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 1a
Type of Violation: Serious; $9,977
29 CFR 1910.132(a): Protective equipment was not used when necessary whenever hazards capable of causing injury and impairment were encountered:
a) Juice Line Area: On or about August 8, 2018 and at times prior to, employee(s) were not provided or required to use heat and water retardant personal protective clothing and/or apron when necessary for hazards of 175 degree Fahrenheit water while conducting sanitation work tasks to include line connection and disconnection of the Clean In Place (CIP) system.
Citation 1 Item 1b
Type of Violation: Serious
29 CFR 1910.132(d)(2): The employer did not verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated, the person certifying that the evaluation has been performed, the date(s) of the hazard assessment, and, which identifies the document as a certification of hazard assessment:
a) Juice Line Area: On or about August 8, 2018 and at times prior to, the employer failed to verify in writing a hazard assessment of tasks performed during sanitation such as but not limited to the line connection and disconnection operation of the Clean In Place (CIP) system had been performed.
Citation 1 Item 2
Type of Violation: Serious; $9,977
29 CFR 1910.147(d)(3): All energy isolating devices that were needed to control the energy to the machine or equipment were not physically located and operated in such a manner as to isolate the machine or equipment from the energy source(s):
a) Juicer Line Area: On or about August 8, 2018 and at times prior to, the employer did not ensure energy isolation devices were located and operated in such a manner to isolate stored energy in the form of 175 degrees Fahrenheit water during sanitation work tasks exposing employees to burns.
Citation 2 Item 1
Type of Violation: Other-than-Serious; $0.00
29 CFR 1910.147(c)(5)(ii)Lockout devices and tagout devices were not singularly identified:
a) Juicer Line area: On or about August 8, 2018, and at times prior to, the employer exposed employees to mechanical and electrical hazards by not ensuring lock(s) used for lockout/tagout of equipment had employee identification on them or identified singularly.
Citations from 2nd Inspection after the 2nd accident
Citation 1 Item 1
Type of Violation: Serious; $12,934 29
CFR 1910.147(d)(4)(i): Lockout or tagout devices were not affixed to each energy isolating device by authorized employees:
a) Elmor Filler Machine: On or about August 8, 2018, and at times prior to, the employer exposed employees to mechanical, electrical and pneumatic hazards by not ensuring that the Elmor Filler Machine had energy sources isolated by a lockout or tagout device. Energy sources included 220 volt electrical and 80 psi pneumatic while employee(s) were performing sanitation work tasks.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 1 Item 2a
Type of Violation: Serious; $10,163 29
CFR 1910.1030(c)(1)(i): The employer having employee(s) with occupational exposure did not establish a written Exposure Control Plan designed to eliminate or minimize employee exposure:
a) Facility wide: On or about August 8, 2018, and at times prior to, the employer has employees performing tasks such as cleaning up blood and other potentially infectious materials following employee injuries and does not have a Blood Borne Pathogen Program in place.
Citation 1 Item 2b
Type of Violation: Serious
29 CFR 1910.1030(f)(1)(i): The employer did not make available hepatitis 8 vaccine and vaccination series to all employees who have occupational exposure:
a) Facility wide: On or about August 8, 2018, and at times prior to, the employer has employees performing tasks such as cleaning up blood and other potentially infectious materials following employee injuries and did not make available the hepatitis B vaccine and vaccination series prior to assigning the employees work where they were exposed to blood.
Citation 1 Item 2c
Type of Violation: Serious
29 CFR 1910.1030(f)(3): Following a report of an exposure incident, the employer did not make immediately available to the exposed employee a confidential medical evaluation or follow-up:
a) Facility wide: On or about August 8, 2018, and at times prior to, the employer exposed employees to bloodborne pathogen hazards from an amputation injury that occurred and did not immediately make available a medical evaluation or post-exposure consultation to employees who assisted the injured employee.
Citation 1 Item 2d
Type of Violation: Serious
29 CFR 1910.1030(g)(2)(i): The employer did not ensure that each employee with occupational exposure participated in a training program:
a) Facility wide: On or about August 8, 2018 and at times prior to, the employer has employees performing tasks such as cleaning up blood and other potentially infectious materials following employee injuries and did not have initial training in place for Blood Borne Pathogens or Universal Precautions for employees(s) that would assist or provide first aid during accidents or injuries or perform post-accident cleaning.
Citation 2 Item 1
Type of Violation: Repeat; $60,973
29 CFR 1910.147(c)(4)(ii)(B): The energy control procedures did not clearly and specifically outline the steps for shutting down, isolating, blocking and seeming machines or equipment to control hazardous energy.
a) Elmor Filler Machine: On or about August 8, 2018, and at times prior to, the employer exposed employees to hazards by not ensuring that the machine had clearly stated techniques for isolating the electrical and pneumatic energy sources.
The business was previously cited for a violation of this occupational safety and health standard or its equivalent standard 29 CFR 1910.147 (c)(7)(I)(B), which was contained in OSHA inspection number 1258192, citation number 1, item number 3 and was affirmed as a final order on 10/18/2017, with respect to a workplace located in Brundidge, AL 36010.
Citation 2 Item 2
Type of Violation: Repeat; $60,973
29 CFR 1910.147(c)(7)(i)(B): Affected employees were not instructed in the purpose and use of the energy control procedure:
a) Elmor Filler Machine: On or about August 8, 2018 and at times prior to, the employer exposed employees to mechanical, electrical and pneumatic hazards by not ensuring that the employees performing sanitation work tasks on the Elmor Filler Machine bad training on affected employee energy control procedures.
The business was previously cited for a violation of this occupational safety and health standard or its equivalent standard 29 CFR 1910.147(c)(7)(1)(8), which was contained in OSHA inspection number 1258192, citation number 1, item number 4b and was affirmed as a final order on 10/18/2017, with respect to a workplace located in Brundidge, AL 36010.
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