OSHA found that the nation’s largest chicken producer failed to use proper safety procedures that allowed a release of 79 pounds of anhydrous ammonia and endangered workers at its Waco facility on Sept. 28, 2015. OSHA cited the facility for two repeat and two serious violations under its Process Safety Management Standard. The company faces penalties of $122,500. OSHA issued the two repeat citations for failing to implement proper standard operating procedures with accurate information on safety systems and how they worked. The company’s process hazard analysis failed to address issues in the plant. Inspectors also found the company’s inspections and equipment testing were not completed as scheduled or documented as required. The agency cited the company for the same or similar violations at its plants in in TX in February 2015 and in Arkansas in July 2013. The agency also issued serious citations for failing to use proper methods to prevent over-pressurization and explosions in the system, and for placing the control and maintenance room facilities in the engine room for ammonia refrigeration. Here is a breakdown of the citations:
Citation 1 Item 1
Type of Violation: Serious; $7,000
29 CFR 1910.119(d)(3)(i)(D): Information pertaining to the equipment in the process did not include relief system design and design basis:
The employer failed to ensure that process safety information included the pressure relief design and design basis. This violation was observed in the new and old ammonia refrigeration system engine rooms on or about October 1, 2015 and at times prior thereto, when the employer failed to document the design and design basis information for the relief headers for the entire ammonia refrigeration process system.
This condition exposed employees to hazards of fire and explosion or inhalation of ammonia vapors.
Citation 1 Item 2
Type of Violation: Serious; $7,000
29 CFR 1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process.
The employer failed to ensure the hazards of the process were addressed. This violation was observed in the ammonia refrigeration engine room on or about October 1, 2015 and at times prior thereto, when the employer failed to ensure the process hazard analysis addressed the hazards associated with locating the control room and maintenance facilities within the ammonia refrigeration engine room.
This condition exposed employees to hazards of fire and inhalation hazards.
Citation 2 Item 1
Type of Violation: Repeat; $70,000
29 CFR 1910.119(d)(3)(ii): The employer did not document that the equipment in the process complied with recognized and generally accepted good engineering practices.
The employer failed to document that equipment in the process complied with recognized and generally accepted good engineering practices (RAGAGEP).
a) The violation was observed on or about October 01, 2015 and at times prior thereto in “new” and “old” engine rooms when the employer failed to document that detectors activate visual and audible alarms outside each entrance to refrigeration machinery rooms in accordance with RAGAGEP such as ANSI/IIAR 2-2008 where employees were exposed to fire or inhalation hazards of ammonia.
b) The violation was observed on or about October 01, 2015 and at times prior thereto in engine room when the employer failed to document that ventilation controls were located outside the principal entrance to engine room in accordance with RAGAGEP such as ANSI/IIAR 2-2008 and/or ANSI/ASHRAE 15-2010 where employees were exposed to fire or inhalation hazards of ammonia.
c) The violation was observed on or about October 01, 2015 and at times prior thereto in engine room when the employer failed to document that emergency stops were located immediately outside principal entrance to engine room in accordance with RAGAGEP such as ANSI/IIAR 2-2008 and/or ANSI/ASHRAE 15-2010 where employees were exposed to fire or inhalation hazards of ammonia.
d) The violation was observed on or about October 01, 2015 and at times prior thereto in engine room when the employer failed to document that the allowable piping discharge lengths were in accordance with RAGAGEP such as ANSI/ASHRAE 15-2010 where employees were exposed to fire or inhalation hazards of ammonia.
Repeat language for instances d:
COMPANY WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD OR ITS EQUIVALENT STANDARD 29 CFR 1910.119(d)(3)(ii), WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER #1001857, CITATION NUMBER 1, ITEM NUMBER 1 AND WAS AFFIRMED AS FINAL ORDER ON MARCH 25, 2015, WITH RESPECT TO A WORKPLACE LOCATED IN TX.
Repeat language for instance a, b, c:
COMPANY WAS PREVIOUSLY CITED FORA VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD OR ITS EQUIVALENT STANDARD 29 CFR 1910.119(d)(3)(ii), WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER #844143, CITATION NUMBER 2, ITEM NUMBER 1 AND WAS AFFIRMED AS FINAL ORDER ON JUNE 13, 2014, WITH RESPECT TO A WORKPLACE LOCATED IN AR.
Citation 2 Item 2
Type of Violation: Repeat; $38,500
29 CFR 1910.119(j)(4)(iv): The documentation of the inspection or test that been performed on process equipment to maintain its mechanical integrity 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, and the results of the inspection or test.
The employer does not ensure inspections and tests performed on process equipment are documented with the date, serial number or equipment identifier, a description, and the result(s) of the inspection or test.
This violation was observed in the “new” and “old” ammonia refrigeration engine rooms on or about October 1, 2015 and at times prior thereto, when the employer failed to ensure inspections and tests performed on ammonia refrigeration system cutouts were documented with the date, serial number or equipment identifier, a description of the test/inspection performed, and the result(s) of the inspection or test. Identified cutouts include but are not limited to Compressor Discharge High/Low Pressure, Compressor High/Low Oil Pressure Differential, Compressor High Discharge Temperature, and High/Low Vessel Levels. This condition exposed employees to fire, explosion, and inhalation hazards.
COMPANY WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD OR ITS EQUIVALENT STANDARD 29 CFR 1910.119G)(4)(iv), WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER #844143, CITATION NUMBER 1, ITEM NUMBER 8bAND WAS AFFIRMED AS FINAL ORDER ON JUNE 13, 2014, WITH RESPECT TO A WORKPLACE LOCATED IN AR.
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