OSHA has cited a beef processing plant after an employee suffered severe burns caused by exposure to anhydrous ammonia, the plants refrigerant. The beef processing plant faces penalties of $182,926 for 16 serious safety violations. OSHA cited the company for process safety management (PSM) program deficiencies, failing to guard roof openings, and electrical safety and lockout/tagout violations. Here is a breakdown of the citations:
- Skylight Fall Hazards
- No Ventilation Design Basis, along with the engine room not being built as a Class I, Div 2 HAZLOC
- Pipe Labeling and King Valve Labeling
- PHA failed to list or address any potential consequences of ammonia being vented back into the plant
- Ammonia vessel not protected from vehicular impact
- No safe work practices (e.g. LOTO) for employees and contractors performing maintenance activities on covered processes
- No audio or visual alarms are in or outside of the engine room
- EAP did not include procedures for handling small releases
- No specific LOTO procedures for the Four Quarter Saw on the Chuck Line and the Brisket Saw
- No eyewash available outside of the engine room
- Eyewash in the engine room was not accessible due to a cabinet that was used to store extra parts
- No fire extinguisher educational program in place, yet policy is for employees to fight incipient fires
- Electrical boxes on Compressors 1, 2, and 3 had missing covers, exposing live wires
- Outlet box in the damp processing room that had a broken cover exposing electrical conductors
- New employees not trained at the time of their initial assignment with the hazards of ammonia
Citation 1 Item 1
Type of Violation: Serious; $9,239
29 CFR 1910.28(b)(3)(i): The employer must ensure each employee is protected from falling through any hole (including skylights) that is 4 feet (1.2 m) or more above a lower level:
The employer is failing to protect employees from fall hazards.
Where the employer has unprotected employees working on the roof of the structure exposed to fall hazards from the three inadequately protected skylights.
Citation 1 Item 2
Type of Violation: Serious; $12,934
29 CFR 1910.119(d)(3)(i)(E): The employer did not have a compilation for written process safety information pertaining to the ventilation system design:
The employer is failing to protect employees from chemical hazards associated with the anhydrous ammonia refrigeration system.
The employer is failing to provide Process Safety Information for the ventilation system in the engine room or the design basis for the ventilation. The engine room has no documented calculations that show the installed ventilation system in the engine room is sufficient for the engine room.
Citation 1 Item 3
Type of Violation: Serious; $9,239
29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices:
a) On or about July 24, 2018, the employer did not document that it complied with recognized and generally accepted good engineering practice (RAGAGEP), such as ANSI/IIAR 2-2014; ANSI/ASHRAE Standard 15-2013; and IIAR Bulletin 109, Section 4.7.6, when it did not ensure that ammonia refrigeration piping was labeled.
b) On or about July 24, 2018, the employer did not document that it complied with recognized and generally accepted good engineering practice (RAGAGEP), such as ANSI/IIAR 2-2014; ANSI/ASHRAE Standard 15-2013; and IIAR Bulletin 109, Section 4.10.3, when it did not ensure the main shut off valve (King Valve) was clearly labeled.
Citation 1 Item 4
Type of Violation: Serious; $12,934
29 CFR 1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process:
The employer is failing to protect employees from chemical hazards associated with the anhydrous ammonia refrigeration system. The 2016 Process Hazard Analysis was performed, however, it failed to list or address any potential consequences of ammonia being vented back into the plant.
Citation 1 Item 5
Type of Violation: Serious; $12,934
29 CFR 1910.119(e)(3)(v): Facility siting was not addressed to ensure process safety equipment was protected from impact:
The employer is failing to protect employees from chemical hazards associated with the anhydrous ammonia refrigeration system.
The employer failing to ensure that an ammonia vessel was protected from vehicular impact. The ammonia receiver is in a pathway toward the maintenance shop and the company has failed to install any barriers to protect the receiver from being struck by vehicular impact.
Citation 1 Item 6
Type of Violation: Serious; $12,934
29 CFR 1910.119(f)( 4): The employer did not develop or implement safe work practices for employees and contractors performing maintenance activities on covered processes:
The employer is failing to protect employees from chemical bum hazards associated with the anhydrous ammonia refrigeration system.
The company has standard operating procedures written for operations for the ammonia refrigeration system; however, they fail to include procedures for de-energizing or making safe the system components prior to any activity were the ammonia could be released.
The operating procedures fail to outline procedures for locking out the covered equipment.
Citation 1 Item 7
Type of Violation: Serious; $12,934
29 CFR 1910.119(j)(2): The employer did not establish or implement written procedures to maintain the on-going integrity of process equipment:
The employer is failing to protect employees from chemical burn hazards associated with the anhydrous ammonia refrigeration system.
The company has a mechanical integrity program with some standard operating procedures for changing out process equipment; however, they have not developed procedures for multiple pieces of process equipment such as; but not limited to, Compressor #2 and the Unit in AC # 1.
Citation 1 Item 8
Type of Violation: Serious; $12,934
29 CFR 1910.119(j)(5): Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside acceptable limits ( defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation:
The employer is failing to protect employees from chemical hazards associated with the anhydrous ammonia refrigeration system.
The employer is failing to provide Process Safety Information for the safety system in the engine room, specifically no audio or visual alarms are in or outside of the engine room. The engine room is not equipped with alarms that audibly or visually indicate that an ammonia leak is present. Its chosen recognized and generally accepted good engineering practice (RAGAGEP), ANSI/IIAR 2-2014 ANSI/IIAR 2-2014 (Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems), Section 6.13.1 states that for ammonia detection for machinery rooms, audible and visual alarms shall be provided inside the room to warn that access to the room is restricted to authorized personnel and emergency responders when the alarm has activated.
Citation 1 Item 9
Type of Violation: Serious; $12,934
29 CFR 1910.119(n): The emergency action plan did not include procedures for handling small releases:
The employer is failing to protect employees from chemical burn hazards associated with the anhydrous ammonia refrigeration system.
In the company written emergency action program, there is no information for how employees are to differentiate between small releases and large releases and how to respond.
Citation 1 Item 10
Type of Violation: Serious; $9,239
29 CFR 1910.147(c)(4)(i): Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:
The employer is failing ensure that employees are protected from the hazards of amputations and electrocutions.
There was no documentation provided by the employer that showed specific procedures for locking out equipment, including but not limited to the Four Quarter Saw on the Chuck Line and the Brisket Saw.
Citation 1 Item 11
Type of Violation: Serious; $12,934
29 CFR 1910.151(c): Where employees were exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use:
a) The employer failed to ensure that an eyewash station was available for use outside of the engine room near the ammonia receiver and process equipment.
b) The employer failed to ensure in the engine room the eyewash shower was accessible due to a cabinet that was used to store extra parts obstructing the eyewash shower.
Citation 1 Item 12
Type of Violation: Serious; $9,239
29 CFR 1910.157(g)(1): Where the employer has provided portable fire extinguishers for employee use in the workplace, the employer did not provide an educational program to familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage fire fighting:
The employer is failing to protect employees from fire hazards. In the company written emergency action program, there is information for designated employees to be trained to fight incipient stage fires. There is no educational program in place for these employees.
Citation 1 Item 13
Type of Violation: Serious; $12,934
29 CFR 1910.305(b)(2)(i): Pull boxes, junction boxes, and fittings were not provided with covers approved for the purpose:
The employer is failing to ensure that the workplace was free from electrical hazards.
In the engine room, there were electrical boxes on Compressors 1, 2, and 3 that had missing covers, exposing electrical wires.
Citation 1 Item 14
Type of Violation: Serious; $9,239
29 CFR 1910.305(e)(1): Cabinets, cutout boxes, fittings, boxes, and panelboard enclosures in damp or wet locations were not installed to prevent moisture or water from entering and accumulating within the enclosures:
The employer is failing to ensure that the workplace was free from electrical hazards. There was an outlet box in the damp processing room that had a broken cover exposing electrical conductors.
Citation 1 Item 15
Type of Violation: Serious; $12,934
29 CFR 1910.307(c)(2)(i): Equipment in hazardous (classified) location(s) was not approved for the ignitable or combustible properties of the specific gas, vapor, dust, or fiber that was or could be present:
The employer is failing to ensure that the workplace was free from explosion hazards. The electrical installations throughout the engine room are not designed for Class 1, Division 2 locations where flammable gases may be present in the area. This room contains refrigeration equipment utilizing anhydrous ammonia which is a flammable gas.
Citation 1 Item 16
Type of Violation: Serious; $7,391
29 CFR 1910.1200(h): Employees were not provided effective information and training as specified in 29 CFR 1910.1200(h)(1) and (2) on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard was introduced into their work area:
The employer is failing to protect employees from chemical burn hazards.
The employer did not ensure that employees were provided with effective information and training in their work area at the time of their initial assignment with the hazards of ammonia.
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