Responding to a complaint from employees at a facility operated by the fourth largest foodservice distributor in the U.S., OSHA found that a check valve in the food plant’s pump room leaked about 9 pounds of anhydrous ammonia on Oct. 21, 2015. Inspectors also found the ammonia sensor in the pump room did not sound an alarm as expected. OSHA’s inspection identified several deficiencies in the Process Safety Management program. As a result of its findings, OSHA cited the business on April 20, 2016, for six serious and two repeated violations of workplace health standards. The company faces a total of $72,000 in proposed penalties. In this case, the process is the facility’s refrigeration system which uses 27,500 pounds of anhydrous ammonia. The deficiencies included:
Citation 1 Item 1
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(2): The employer did not establish or implement ·written procedures to maintain the on-going integrity of process equipment:
Refrigerated Warehouse:
On or about October 21, 2015, employer did not establish and implement effective written procedures for inspection and testing of checK valves such as checK valve (GHX2.05) downstream from solenoid valve GHX2.04 in accordance with the manufacturer’s safety procedures for the servicing or replacement of the check valves so that they are replaced before any failure occurs.
Citation 1 Item 2
Type of Violation: Serious; $7,000
29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment was not consistent with applicable manufacturers’ recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience:
Refrigerated Warehouse:
a) A check valve (GHX2.05) had not been tested or replaced in the intervals consistent with applicable manufacturer’s recommendations. Employer had not determined alternative good engineering practices.
b) The employer’s replacement intervals for the ammonia sensors were not consistent with the applicable manufacturer’s recommendations. Employer had not determined alternative good engineering practices.
Citation 1 Item 3
Type of Violation: Serious; $7,000
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) in a safe and timely manner when necessary means where taken to assure safe operation.
Refrigerated Warehouse:
On or about October 21, 2015, employer did not ensure that the alarms on the ammonia sensors devices were functioning adequately.
Citation 1 Item 4
Type of Violation: Serious; $7,000
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):
Establishment:
On or about October 21, 2015, employer’s Emergency Planning and Response Plan (EPRP) did not address the following minimum requirements of this standard in the event of an accidental release/leak of ammonia refrigerant:
– (ii) Current personnel roles and lines of authority.
– (iii) Emergency recognition and prevention.
– (iv) Safe distances and places of refuge.
– (ix) Emergency alerting and response procedures.
Citation 1 Item 5
Type of Violation: Serious; $7,000
29 CFR 1910.120(q)(3)(ii): The individual in charge of the incident command system did not identify, to the extent possible, all hazardous substances or conditions present and did not address, as appropriate, site analysis, use of engineering controls, maximum exposure limits, hazardous substance handling procedures and the use of any new technologies:
Establishment:
On or about October 21, 2015, the employer did not take adequate precautions to identify maximum exposure limits to ammonia refrigerant.
Citation 1 Item 6
Type of Violation: Serious; $7,000
29 CFR 1910.120(q)(6)(iv): Hazardous materials specialists did not receive at least 24 hours of training equal to the technician level and/or in addition have competency in the areas outlined in 1910.120(q)(6)(iv)(A) through (q)(6)(iv)(I) and/or the employer did not so certify:
Establishment:
On or about October 21, 2015, employer did not ensure that employees who respond with and provide support to hazardous materials technicians demonstrated the competency in areas outline by this section.
Citation 2 Item 1
Type of Violation: Repeat; $15,000
OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to the hazards associated with being crushed or struck by falling objects:
Refrigerated Warehouse, Cooler Deli CO Aisle:
The commercial steel storage racks used to store boxes and pallets of food product such as milk, eggs and cheese, and other dairy products, deli meats, and said dressing were not maintained to prevent the collapse of racks.
Columns of the storage racks that stored boxes and pallets of food products were not anchored adequately to the floor.
Anchor bolts were significantly damaged, unsecured or sheared. Instances included, but were not limited to; column numbers C06505/C06701, C05305/C05501, and C05705/C05901.
Impact panels secured to the columns were also unsecured.
The company was previously cited for a violation of this occupational safety and health standard or its equivalent standard, which was contained in OSHA inspection number #1008076, citation number 1, item number 1 and was affirmed as a·final order on April 1, 2015, with respect to a workplace located in MA.
One feasible method of abatement includes but is not limited to:
1. Install anchors for the columns and the impact panels capable of resisting shear forces caused by horizontal and vertical loads on the rack.
Citation 2 Item 2
Type of Violation: Repeat; $15,000
29 CFR 1910.305(b)(1)(ii): Unused openings in boxes, cabinets, or fittings were not effectively closed:
Chicken Aisle of Cooler adjacent to entrance to -10 Freezer:
The following electrical cabinets and boxes were not effectively closed:
a) Disconnect for the door blower had a missing knockout on the left side and a knockout missing on the bottom
b) Pad-3 red panel for the fire alarm/extinguishing system had a knockout missing on the left side.
The company was previously cited for a violation of this occupational safety and health standard or its equivalent standard, which was contained in OSHA inspection number #911586, citation number 1, item number 4. and was affirmed as a final order on December 13, 2013, with respect to a workplace located in MA.
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