OSHA has cited a food manufacturing company for 25 serious and one other violation for exposing workers to hazardous chemicals, electrical dangers and fall hazards. OSHA discovered the violations after an inspection of the facility. The agency inspected the plant after an evacuation of the facility sent workers to the hospital as a precaution on Oct. 16, 2015. The citations include multiple violations of OSHA’s process safety management regulations; exposing workers to hazardous chemicals, respiratory protection, electrical hazards, and the failure to provide fall protection to employees. Proposed penalties for the employer total $124,000. Here’s a breakdown of the PSM and PSM Related citations:
1st Set of Citations
Citation 1 Item 1
Type of Violation: Serious; $7,000
29 CFR 1910.119(d)(3)(i)(D): Process safety information pertaining to the equipment in the process did not include relief system design and design basis.
On or about 10/20/2015 the employer did not document the relief system design and design basis for the ammonia refrigeration system exposing employees to toxic hazards of ammonia exposure.
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; $7,000
29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP).
a. On or about 10/20/2015, the employer did not document that it complied with recognized and generally accepted good engineering practice such as ANSI/ ASHRAE-15 (American Society of Heating Refrigeration AirConditioning and Engineering) and ANSI/IIAR-2 (International Institute Ammonia Refrigeration) as it failed to install visual and audible alarms outside the engine room entrance doors exposing employees to the hazards of dangerous concentrations of ammonia following a release in the engine room.
b. On or about 10/20/2015, the employer did not document that it complied with recognized and generally accepted good engineering practice such as ANSI/ ASHRAE-15 (American Society of Heating Refrigeration AirConditioning and Engineering) when it failed to set ammonia detectors in the engine room at a value not greater than TLV-TWA (Threshold limit value-time weighted average) exposing employees to toxic hazards of ammonia exposure.
c. On or about 10/20/2015, the employer did not document that it complied with recognized and generally accepted good engineering practice such as ANSI/ASHRAE-15 (American Society of Heating Refrigeration AirConditioning and Engineering) when it failed to ensure that alarms would activate upon failure of the ventilation system in the machine room exposing employees to fire, explosion, and toxic hazards following an ammonia release.
d. On or about 10/20/2015, the employer did not document that it complied with recognized and generally accepted good engineering practice such as ANSI/ ASHRAE-15 (American Society of Heating Refrigeration AirConditioning and Engineering) and ANSI/IIAR-2 (International Institute Ammonia Refrigeration) when it failed to post an authorized personnel sign on the West entrance door of the engine room exposing employees to toxic hazards of ammonia exposure.
e. On or about 10/20/2015, the employer did not document that it complied with recognized and generally accepted good engineering practice such as ANSI/IIAR-2 (International Institute Ammonia Refrigeration) when it failed to install an accessible eyewash and body shower station outside of the engine room exit exposing employees to toxic hazards of ammonia exposure.
Citation 1 Item 2b
Type of Violation: Serious; GROUPED
29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits in a timely manner.
a) On or about 10/20/2015, the employer failed to correct deficiencies in the mechanical ventilation system, in that it could not be activated by an ammonia detector or it ran continuously and was not provided with a supervisory alarm to detect failure or shutdown of the system exposing employees to the hazards of inhalation of ammonia and fire/explosion. As a result of this deficiency, the engine room does not conform to the requirements of Class 1, Division 2 hazardous location, of the National Electrical Code and ANSI/ ASHRAE-15 (American Society of Heating Refrigeration Air-Conditioning and Engineering)
b) On or about 10/20/2015, the employer failed to correct deficiencies in the ammonia refrigeration emergency control system when emergency control switches for ventilation fans were not installed/located immediately outside the engine room door in accordance with ANSI/ ASHRAE-15 (American Society of Heating Refrigeration Air-Conditioning and Engineering) and ANSI/IIAR-2 (International Institute Ammonia Refrigeration) exposing employees to the hazards of inhalation of ammonia and fire/explosion.
Citation 1 Item 3
Type of Violation: Serious; $7,000
29 CFR 1910.119(e)(5): The employer did not assure that PHA recommendations were resolved in a timely manner.
On or about 10/20/2015, the employer did not resolve 2012 PHA recommendations in a timely manner such as but not limited to:
a. Item# 1.4: Perform a RV Design calculation to verify RV meets minimum required capacity.
b. Item# 5.18: Install pipe labels per ASME 13.1 to piping in cold rooms. Install warning detection below drain pan of air units.
This condition exposed employees to the hazards of inhalation of ammonia and fire/explosion.
Citation 1 Item 4
Type of Violation: Serious; $7,000
29 CFR 1910.119(f)(1): The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information.
On or about 10/20/2015, the employer did not develop and implement written operating procedures for operating the Emergency Dump (water) Tank exposing employees to toxic hazards of ammonia exposure.
Citation 1 Item 5
Type of Violation: Serious; $5,000
29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment.
On or about 10/20/2015, the employer did not ensure that the full independent inspections on pressure vessels and heat exchangers were conducted such as but not limited to the following:
a. Re-circulator, V-4 (on PID 10)
b. High Pressure Receiver, VI (on PID07) c. Evaporative Condenser, EC-1 (PID05) This condition exposed employees to the hazards of inhalation of ammonia and fire/explosion.
Citation 1 Item 6
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment.
On or about 10/20/2015, the employer did not test or calibrate ammonia detectors for the ammonia refrigeration systems such as but not limited to the following:
a. Two ammonia detectors located in the engine room
b. One ammonia detector located on the roof of the engine room at the SRV (Safety Relief Valve) Relief Vent Header
This condition exposed employees to the hazards of inhalation of ammonia and fire/explosion.
Citation 1 Item 7
Type of Violation: Serious; $7000
29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment to maintain its mechanical integrity, was not consistent with applicable manufacturers’ recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.
a) On or about 10/20/2015, the employer failed to ensure that safety inspections for the ventilation system in the engine room was conducted at a frequency consistent with recognized and generally accepted good engineering practice such as IIAR Bulletin No.109 and the. employer’s Mechanical Integrity (MI) procedure.
This condition exposed employees to the hazards of inhalation of ammonia and fire/ explosion.
b) On or about 10/20/2015, the employer did not ensure that inspections and tests are conducted at a frequency consistent with recognized and generally accepted good engineering practice such as IIAR Bulletin No.110 and the employer’s Mechanical Integrity (Ml) procedures for specific safety systems that include but are not limited to the following:
1. Oil Pressure Differential Cut Outs for the Compressor, HS-1
2. High and Low Pressure Cut Out for the compressor, HS-2
3. High Temperature Cut Out for Compressor, BC-1
4. High and Low Level Controls for Re-circulator, V-4
5. High and Low Level Controls for High Pressure Receiver, V-1
6. Emergency Stop Buttons for the ammonia refrigeration system
This condition exposed employees to the hazards of inhalation of ammonia and fire/explosion.
c) On or about 10/20/2015, the employer did not ensure that inspections and tests are conducted at a frequency consistent with recognized and generally accepted good engineering practice such as the employer’s Mechanical Integrity (Ml) procedures and IIAR Bulletin No.110 for compressors and pumps that include but are not limited to the following:
1. High Stage Compressor, HS-1
2. Booster Compressor, BC-1
3. Recirculator Pump, RP-1
4. Recirculator Pump, RP-2
This condition exposed employees to the hazards of inhalation of ammonia and fire/explosion.
d) On or about 10/20/2015, the employer did not ensure that inspections and tests are conducted at a frequency consistent with recognized and generally accepted good engineering practice such as IIAR Bulletin No.110 and the employer’s Mechanical Integrity (MI) procedures for piping that include but are not limited to the following:
1. 1O” LTRS (Low Temperature Recirculation suction) header.
2. 6” HSD (High Stage Discharge) from High Stage Compressors to Evaporated Condensers (EC-l&EC-2)
3. 3″ HPL (High Pressure Liquid) from the King Valve to the Intercooler V-3.
4. 6″ BD (Booster Discharge) from Booster compressors to the Intercooler V-3.
This condition exposed employees to the hazards of inhalation of ammonia and fire/explosion.
Citation 1 Item 8
Type of Violation: Serious; $5,000
29 CFR 1910.119 (l)(1): The employer did not establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.
On or about 12/08/2015, the employer did not establish and implement written procedures for managing changes to ammonia detectors (located in the engine room) which were being installed exposing employees to toxic hazards of ammonia exposure.
CLICK HERE for the citations
2nd Set of Citations
Citation 1 Item 1
Type of Violation: Serious; $5,000
OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which was free from recognized hazards that were causing or likely to cause death or serious physical harm to employees. Employees were exposed to health hazards associated with anhydrous ammonia:
On or about 10/16/2015, in the ammonia refrigeration area, during an ammonia release event employees were exposed to anhydrous ammonia while using the GasAlert Extreme ammonia detector that had not been calibrated and bump-tested. A feasible means of abatement includes, but is not limited to calibrating the meter and performing bump-testing per the instructions in the User Manual of the GasAlert Extreme.
Citation 1 Item 2
Type of Violation: Serious; $7,000
OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which was free from recognized hazards that were causing or likely to cause death or serious physical harm to employees.
Employees were exposed to an asphyxiation hazard associated with nitrogen:
On or about 10/16/2015, the employer did not implement proper controls inside the spiral freezer to ensure that the release of nitrogen did not result in the displacement of oxygen.
A feasible means of abatement includes, but is not limited to installing mechanical ventilation in the nitrogen freezer room as stated on pages 3-3 and 4-6 of the CES Nitrogen Freezer’s Maintenance and Service Manual, using an isolation means for the liquid nitrogen line on the freezer such as blinding or double-block and bleed, and ensuring that oxygen sensors are regularly calibrated.
Citation 1 Item 3
Type of Violation: Serious; $7,000
OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which was free from recognized hazards that were causing or likely to cause death or serious physical harm to employees.
Employees were exposed to a struck-by hazard associated with a collapsing storage rack.
On or about 10/16/2015, in the loading dock area, the employer allowed employees to operate forklifts and access walkways near storage racks with the following deficiencies: missing anchor bolts, corroded and damaged structural components, no posted load ratings, and out-of-straight support columns.
A feasible means of abatement includes, but is not limited to installing racks that meet ANSI MH 16.1 standard or repair existing racks so they meet the standard by having anchor bolts, straight columns, plaques with load ratings, and are free from damage.
Citation 1 Item 4
Type of Violation: Serious; $5,000
29 CFR 1910.23(a)(2): Ladderway floor opening(s) or platform(s) were not guarded by a standard railing with standard toeboard(s) on all exposed sides (except at the entrance to opening) with passage through the railing either provided with a swinging gate or so offset that a person could walk directly into the opening:
a) On or about 10/16/2015, on the roof condenser platform, the employer allowed employees to conduct rounds and make repairs near a ladderway floor opening which lacked a swinging gate to guard the passage through the railing.
b) On or about 10116/2015, on the top of the emergency dump tank, the employer did not ensure that the passage through the railing of the ladderway floor opening was guarded by a swinging gate.
Citation 1 Item 5
Type of Violation: Serious; $3,000
29 CFR 1910.23(a)(8): Every floor hole into which persons can accidentally walk were not guarded:
On or about 10/16/2015, on the second level platform in the liquid nitrogen freezer room, the employer allowed employees to work from the platform more than 10 feet above the lower level and did not ensure that a 10 inch opening behind the liquid nitrogen freezer was guarded.
Citation 1 Item 6
Type of Violation: Serious; $5,000
29 CFR 1910.23(b)(4): Every temporary wall opening did not have adequate guards:
On or about 10/16/2015, on the second level platform in the nitrogen freezer room, the employer allowed employees to work on the second level platform while placing the nitrogen freezer out-of-service and did not ensure that the freezer hatch was guarded when opened.
Citation 1 Item 7
Type of Violation: Serious; $5,000
29 CFR 1910.24(b): Fixed stairs were not provided for access from one structure level to another where operations necessitated regular travel between levels, and for access to operating platforms at any equipment which requires attention routinely during operations:
On or about 10/16/2015, on the roof, the employer allowed employees to conduct daily inspections and routine maintenance of ammonia refrigeration equipment and did not provide fixed industrial stairs from the second floor to the roof or the ground to the roof.
Citation 1 Item 8
Type of Violation: Serious; $5,000
29 CFR 1910.120(q)(2): The employer did not develop an emergency response plan for emergencies which addressed the following minimum requirements of this standard: 1910.120(q)(2)(i) through 1910.120(q)(2)(xii):
On or about 10/16/2015, the employer’s emergency response plan did not include the following minimum requirements of the standard for an emergency release of nitrogen:
Emergency recognition and prevention, safe distances and places of refuge, evacuation routes and procedures, emergency medical treatment and first aid, and PPE and emergency equipment.
Citation 1 Item 9
Type of Violation: Serious; $5,000
29 CFR 1910.120(q)(9)(i): Members of an organized and designated HAZMAT team and hazardous materials specialist did not receive a baseline physical examination and/or was not provided with medical surveillance as required in 29 CFR 1910.120(f):
On or about 10/16/2015, at 109 Highway 1085 in Madisonville, LA, the employer did not ensure that members of the HAZMAT team received a baseline physical examination.
Citation 1 Item 10
Type of Violation: Serious; $4,000
29 CFR 1910.132(a): Protective equipment was not maintained in a sanitary and reliable condition:
On or about 10/16/2015, at 109 Highway 1085 in Madisonville, LA, the employer provided Tychem 10000 protective chemical suits for emergency use, but did not ensure that the suits were inspected and leak tested annually.
Citation 1 Item 11
Type of Violation: Serious; $5,000
29 CFR 1910.134(e)(1): The employer did not provide a medical evaluation to determine the employee’s ability to use a respirator, before the employee was fit tested or required to use the respirator in the workplace:
On or about 10/16/2015, the employer required employees to wear respirators during emergencies and when changing compressor oil and did not ensure that employees had received medical evaluations.
Citation 1 Item 12
Type of Violation: Serious; $5,000
29 CFR 1910.134(f)(2): Employee(s) using tight-fitting facepiece respirators were not fit tested prior to initial use of the respirator:
On or about 10/16/2015, the employer required employees to wear respirators with tight-fitting facepieces during emergencies and when changing compressor oil and did not ensure that employees received fit tests.
Citation 1 Item 13
Type of Violation: Serious; $3,000
29 CFR 1910.253(b)(4)(iii): Oxygen cylinders in storage were not separated from fuel-gas cylinders or combustible materials (especially oil or grease), a minimum distance of 20 feet (6.1 m) or by a noncombustible barrier at least 5 feet (1.5 m) high having a fire-resistance rating of at least one-half hour:
On or about 10/16/2015, in the maintenance shop, the employer allowed employees to conduct tasks such as operating a forklift in an area where oxygen and acetylene cylinders were stored next to each other without a fire resistant barrier.
Citation 1 Item 14
Type of Violation: Serious; $3,000
29 CFR 1910.305(b)(1)(ii): Unused openings in boxes, cabinets, or fittings were not effectively closed:
On or about 12/15/2015, next to the roof access ladder on the second floor, unused openings in a breaker box were not effectively closed.
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 15a
Type of Violation: Serious; $5,000
29 CFR 1910.1200(h)(1): Employees were not provided effective information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard that the employees had not been previously trained about was introduced into their work area:
On or about 10/16/2015, the employer allowed employees to work in areas where liquid nitrogen is used to freeze food and did not provide effective information and training. The employer allowed employees to work in areas with asphyxiants such as nitrogen, flammable gases such as acetylene, compressed gases such as oxygen, caustics such has sodium hydroxide, and anhydrous ammonia and did not provide effective information and training at the time of their initial assignment.
Citation 1 Item 15b
Type ofViolation: Serious; GROUPED
29 CFR 1910.1200(h)(3)(iv): The details of the hazard communication program developed by the employer, did not include an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information and how employee could obtain and use the appropriate hazard information:
On or about 10/16/2015, the employer did not ensure that all employees were trained on the new format for safety data sheets, Global Harmonization System pictograms, new hazard rating system, and warning words.
Citation 2 Item 1
Type ofViolation: Other-than-Serious; $0.00
29 CFR 1910.23(c)(1): Open-sided floors and/or platforms four feet or more above adjacent floor or ground level were not guarded with standard railings (or equivalent) and toeboards:
On or about 10/16/2015, on top of the roof condenser, the employer allowed employees to clean nozzles and did not ensure that railing was provided to prevent a fall of over 10′ in height.
Note: Toeboards are only required when persons can pass, there is moving equipment or there is equipment with which falling materials could create a hazard.
CLICK HERE for the citations