A cold storage business has been cited for 14 safety violations and fined $132,800 by OSHA for exposing workers to anhydrous ammonia at its facility. The company has been placed in OSHA’s Severe Violator Enforcement Program. The March inspection was initially conducted under OSHA’s high-hazard local emphasis program. It expanded to include all items within the agency’s national emphasis program for process safety management for covered chemical facilities. The company provides basic storage and shipping services for the frozen, refrigerated and perishable food industries. The four (4) willful violations cited involve PSM violations, including the failure to develop and implement written, safe operating and mechanical integrity procedures and measures to take for physical contact or airborne exposure to anhydrous ammonia. The remaining violations involve failing to correct deficiencies in equipment and to document responses to 2010 compliance audit findings, including 12 of 22 deficient audit items that remained uncorrected. A total of 10 serious safety violations include lack of emergency action planning; failing to maintain the original ammonia refrigeration systems process hazard analysis; exposing workers to crushing hazards by failing to remove and/or repair damaged storage racks; and failing to evaluate the performance of a powered industrial truck operator every three years. The other violations include failing to prevent electrocution from ice buildup encasing electrical junction boxes; operating equipment within 30 inches of a fork truck charging station; and install fixed wiring and provide strain relief for power cords. Here is a breakdown of the citations…
Citation 1 Item 1
Type of Violation: Serious; $2,800.00
29 CFR 1910.119(d)(3)(i)(B): Process safety information pertaining to the equipment in the process did not include accurate Piping and Instrumentation Diagrams (P&ID)
The Piping and Instrumentation Diagram developed for the system did not include all of the components of the system. Safety Relief Valves (SRV) located on the system compressors vent to a header system which then vents to the roof. The P&ID shows that each SRV vents directly to atmosphere omitting the header systems.
Citation 1 Item 2
Type of Violation: Serious; $2,000.00
29 CFR 1910.119(e)(7): Employers shall retain process hazards analyses and updates or revalidations for each process covered by this section, as well as the documented resolution of recommendations described in paragraph (e)(5) of this section for the life of the process.
The employer failed to maintain the original Process Hazard Analysis for the facility. It was conducted in 1999. This would include the findings, recommendations, and resolutions.
Citation 1 Item 3
Type of Violation: Serious; $2,800.00
29 CFR 1910.119(n): The employer did not implement an emergency plan for the entire plant in accordance with the provisions of 29 CFR 1910.38
The employer has not developed exit routes for the employees to follow in the event of an evacuation. The facility uses ammonia as part of their refrigeration system and a ref ease could harm any employee that does not evacuate to a safe, predetermined area. The evacuation plan should include a method for determining the safe route and rally point utilizing a wind sock to determine the safe upwind predetermined evacuation location.
Citation 1 Item 4
Type of Violation: Serious; $2,000.00
29 CFR 1910.147(c)(7)(i): The employer did not provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees
The employer failed to ensure that any employee involved or affected by Lockout/tagout operations had received the level of training necessary to ensure the safe application, usage and removal of energy control devices.
Citation 1 Item 5
Type of Violation: Serious; $1,600.00
29 CFR 1910.176(b): Storage of material created a hazard (based on improper installation and use).
The storage racks within the cold storage warehouses have sustained damage that change the strength and stability of the system as intended by the manufacturer.
Citation 1 Item 6
Type of Violation: Serious; $1,600.00
29 CFR 1910.178(l)(4)(iii): An evaluation of each po\vered industrial truck operator’s performance was not being conducted at least once every three years
The employer failed to ensure that each operator of a powered industrial truck was evaluated every three years as required. An employee has not had a re-evaluation since 2000.
Citation 1 Item 7
Type of Violation: Serious; $2,000.00
29 CFR 1910.303(g)(1)(i)(B): For electric equipment operating at 600 volts, nominal, or less to ground, and likely to require examination, adjustment, servicing, or maintenance while energized, the width of the working space in front of electrical equipment has less than the width of the equipment or 762 mm (30 inches), whichever was greater
An electrical disconnect (circuit breaker panel) did not have the necessary clear space as identified in 1910.303(g)(1). In this case, the clear space should have been at 30 inches and was limited to 25 inches.
Citation 1 Item 8
Type of Violation: Serious; $2,000.00
29 CFR 1910.305(e)(1): Cabinets, cutout boxes, fittings, boxes, and panel board enclosures in damp or wet locations were not installed to prevent moisture or water from entering and accumulating within the enclosures
Electrical components such as junction boxes and conduit are not designed for exposure to wet or damp locations. In this case, the components are part of the circuits related to an anhydrous ammonia refrigeration system and have become encased in ice (wet location).
Citation 1 Item 9
Type of Violation: Serious; $2,000.00
29 CFR 1910.305(g)(1)(iv)(A): Flexible cords and/or cables were used as a substitute for the fixed wiring of a structure
Engine Room: An extension cord was plugged into an outlet and then run over the top of an overhead door to power a water filtration unit (de-ionizer) used to refill fork truck batteries. The cord had been in place for over 1 year which is beyond temporary use.
Citation 1 Item 10
Type of Violation: Serious; $2,000.00
29 CFR 1910.305(g)(2)(iii): Flexible cords and cables were not connected to devices and fittings so that strain relief is provided that will prevent pull from being directly transmitted to joints or terminal screws
Loading Dock: A fork truck battery charger has a cord which has come away from the plug creating an issue of strain relief. This allowed all of the weight of the cord to be transmitted to the terminal screw’s which can create resistance issues.
Citation 2 Item 1a
Type of Violation: Willful; $28,000.00
29 CFR 1910.119(f)(1)(iii)(B): The employer has failed to develop and implement written operating procedures that provide clear instructions for taking the precautions necessary to prevent exposure; including engineering controls, administrative controls, and personal protective equipment
The employer failed to develop and implement procedures and controls putting into place the precautions necessary to prevent employees from exposure to anhydrous ammonia. The company has not adequately addressed how employees are protected or how they would be protected, e.g., engineering control, PPE, or some other method, in the event of an upset condition.
Citation 2 Item 1b
Type of Violation: Willful; Grouped
29 CFR 191O.119(f)(1)(iii)(C): The employer has failed to develop and implement an operating procedure discussing the control measures to be taken if physical contact or airborne exposure occurs.
The employer did not develop an operating procedure that discusses what actions will be taken in the event of an exposure to anhydrous ammonia. The employer has failed to develop a procedure for response actions for employee exposure that would include but is not limited to event escalation, emergency response, or containment.
Citation 2 Item 2
Type of Violation: Willful; $28,000.00
29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment
The employer has not developed any procedures for ensuring the mechanical integrity of the system. This would include a program outlining preventative maintenance, component replacement, and/or repair. One such example would be a valve replacement procedure to include a change out schedule for safety relieve valves. During the inspection it was also found that the company did not have a piping inspection procedure. Rusted piping was found in a number of locations that had not been mitigated.
Citation 2 Item 3
Type of Violation: Willful; $28,000.00
29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information on paragraph (d) of this section) before further use or in a safe and timely manner when necessary means where taken to assure safe operation
Engine Room: The following deficiencies at the site were not corrected:
a) The employer did not ensure that safety relief valves installed in the ammonia refrigeration system to prevent over-pressurization conditions were changed within the timeframes established by the manufacturer. The valves are to be changed at least every 5 years or in the event of a release. Two valves, 804 A&B, in the engine room were 1 year past due.
b) Rusted piping, damaged insulation and ice buildup in the engine room had not been addressed since originally being identified in 2009. These three items are all related to the ammonia refrigeration process piping and associated components. One instance of icing had encapsulated an ammonia pump and motor to the point where the items were not identifiable.
c) Engine room ventilation motors are not of the explosion proof variety. Due to the flammable nature of anhydrous ammonia, ventilation system that are designed to evacuate any leaked material shall not present an ignition source for the listed highly hazardous chemical. This item was identified in 2009.
d) Engine Room intake vents are not of the fail open variety. In the event the intake vents fail, the required continuous ventilation for the room would be disrupted. This item was identified in 2009.
Citation 2 Item 4
Type of Violation: Willful; $28000.00
29 CFR 1910.119(0)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.
The employer failed to develop a system to track any identified deficiencies noted during the Process Safety Management Audit. There twenty-two items identified in the 2010 audit and no method to track those open items until they were corrected. As of the inspection date, there were still 12 open items from the audit.
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