OSHA has cited a meat packing company for exposing workers to releases of hazardous chemicals. The company faces $615,640 in penalties. OSHA determined that the meat-packing facility failed to implement a required Process Safety Management (PSM) program for operating an ammonia refrigeration unit containing over 10,000 pounds of anhydrous ammonia. The employer also failed to provide fall protection, guard machines and equipment, control hazardous energy, and implement a respiratory protection program.
Here is a break down of the citations:
Citation 1 Item 1
Type of Violation: Serious; $9,472
29 CFR 1910.22(a)(3): Walking/working surfaces were not maintained free of hazards such as sharp or protruding objects, loose boards, corrosion, leaks, spills, snow, and ice:
On or about November 8, 2018, protruding pipes are installed through the steps of the exterior stairway where employees are accessing the roof to perform maintenance, inspections and other activities, exposing employees to a fall hazard of approximately 20 feet to the ground below.
Citation 1 Item 2
Type of Violation: Serious; $9,472
29 CFR 1910.28(b)(1)(i): The employer did not ensure that each employee on a walking-working surface with an unprotected side or edge that was 4 feet (1.2 m) or more above a lower level was protected from falling by one or more of the following: Guardrail systems, safety net systems, or personal fall arrest systems:
On or about November 8, 2018, employees performing maintenance, inspections and other activities on the roof are not provided fall protection, exposing the employees to a fall hazard up to approximately 25 feet.
Citation 1 Item 3
Type of Violation: Serious; $9,472
29 CFR 1910.119(c)(1): The employer did not develop a written plan of action regarding the implementation of the employee participation required by this paragraph:
On or about November 8, 2018, and times prior thereto, the employer failed to consult with employees on the development of process hazard analyses and elements of process safety management. The employer uses over 10,000 pounds of anhydrous ammonia as a refrigerant for the freezers and to cool the processing floor.
Citation 1 Item 4
Type of violation: Serious; $9,472
29 CFR 1910.119(g)(1)(i): The employer did not train each employee before being involved in operating a newly assigned process in the operating procedures as specified in paragraph (f) of this section:
On or about November 8, 2018, and at times prior thereto, the employer did not ensure employees were trained in procedures for normal operations, emergency operations. and the consequence of deviations. The employer uses over 10,000 lbs .of anhydrous ammonia for refrigerant for the freezers and cooling the processing floor.
Citation 1 Item 5
Type of Violation: Serious; $9,472 29
CFR 1910.119(n): Emergency planning and response. The employer did not establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan did not include procedures for handling small releases.
On or about November 8, 2018, and at times prior thereto, the employer did not ensure the emergency action plan addressed procedures for an anhydrous ammonia release. The employer uses over 10,000 lbs of anhydrous ammonia for refrigerant for the freezers and cooling the processing floor.
The plan did not address elements such as, but not limited to:
1. Definition of a small release and protocols for responding to a small releases.
2. Evacuation procedures and mustering/gathering points in the event of an anhydrous ammonia release.
3. Wind sock references to assist in assessing wind flow directions for evacuation routes if necessary.
4. Functional and visible wind socks to indicated wind direction in the event of an anhydrous ammonia release.
*February 16, 2019, on the roof, a valve gasket failed on the evaporator (EV-12) and approximately 50 lbs of anhydrous ammonia was released.
*January 28, 2019, in engine/machinery room, a seal on the purger went bad releasing trace amounts of ammonia.
Citation 1 Item 6
Type of violation: Serious; $9,472
29 CFR 1910.134(c)(1): The employer did not establish and implement a written respiratory protection program with worksite-specific procedures in any workplace where respirators were necessary to protect the health of the employee or whenever respirators were required by the employer.
On or about November 8, 2018, and at times prior thereto, the employer did not ensure that a written respirator program was implemented. Employees are required to wear 3M full-face respirators when maintaining the anhydrous ammonia refrigeration system. The employer has approximately 16,500 lbs of anhydrous ammonia on site.
(i)-Procedures for selecting respirators for use in the workplace;
(ii)-Medical evaluations of employees required to use respirators;
(iii)-Fit testing procedures for tight~fitting respirators;
(iv)-Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations;
(v)-Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding and otherwise maintaining respirators;
(vi)-Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations;
(vii)-Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance; and
(viii)-Procedures for regularly evaluating the effectiveness of the program.
Citation 1 Item 7
Type of Violation: Serious; $9,472
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:
On or about November 8, 2018, and at times prior thereto, the employer failed to ensure energy control procedures were developed for the compressors in the engine/machinery room. The compressors contain hazardous chemicals (anhydrous ammonia) and electrical energy. Employee(s) were exposed to hazards such as, but not limited to electric shock and inhalation of anhydrous ammonia.
Citation 1 Item 8
Type of Violation: Serious; $9,472
29 CFR 1910.147(d)(4)(i): Lockout or tagout devices were not affixed to each energy isolating device by authorized employees:
On or about November 8, 2018 and at times prior thereto, the number two (#2) Mycom compressor was torn apart and locks were not affixed to the two valves isolating the compressor from the system.
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 9a
Type of Violation: Serious; $9,472
29 CFR 1910.219(d)(1): Pulley(s) with part(s) seven feet or less from the floor or work platform were not guarded in accordance with the requirements specified in 29 CFR 1910.2l9(m) and (o):
On or about November 7, 2018, in the engine room, the rotating pulleys on the compressors were not guarded. Employee(s) exposed to a caught-in hazard from the rotating pulley on the compressors.
1. Compressor #1, Vilter compressor R33740, the rotating pulley was not guarded. The guard was missing on the back.
2. Compressor #3, Mycom compressor the rotating pulley was not guarded. The guard was missing on the back.
Citation 1 Item 9b
Type of Violation: Serious; Grouped
29 CFR 1910.219(e)(1)(i): Horizontal belts which had both runs seven feet or less from the floor level were not guarded with a guard that extended to at least fifteen inches above the belt:
On or about November 7, 2018, in the engine room, the rotating belts on the compressors were not guarded. Employee(s) exposed to a caught-in hazard from the rotating belts on the compressors.
1: Compressor #1, Vilter compressor R33740, the rotating belts were not guarded. The guard was missing on the back.
2. Compressor #3, Mycom compressor the rotating belts were not guarded. The guard was missing on the back.
Citation 2 Item 1
Type of Violation: Willful; $132,598
29 CFR 1910.119(d): The employer did not complete a compilation of written process safety information, including information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process before conducting the process hazard analysis:
a) On or about November 8, 2018, and at times prior thereto, the employer failed to have a maximum inventory of the quantity of anhydrous ammonia in the system. The refrigeration system contains approximately 16,500 pounds of anhydrous ammonia for refrigerant for the freezers and to cool the processing floor. The employer presented an intended inventory of 9,867 pounds.
b) On or about November 8, 2018, and at times prior thereto, the employer failed to ensure piping and instrument diagrams (P&ID) were updated and correct. The P&ID’s were not updated and did not show the isolation valves for the #2 compressor was taken off line.
c) On or about November 8, 2018, and at times prior thereto, the employer failed to ensure they maintained a current listing and function for the pressure relief valves. The employer uses over 10,000 pounds of anhydrous ammonia for refrigerant for the freezers and to cool the processing floor.
d) On or about November 8, 2018, and at times prior thereto, the employer failed to ensure the anhydrous ammonia receiver (V0-1) was protected from being struck by vehicles and/or equipment in accordance with Recognized and Generally Good Engineering Practices (RAGAGEP), such as but not limited to, the guidance set forth in International Institute of Ammonia Refrigeration IIAR 2, 2014, Section 7.2.4.
e) On or about November 8, 2018, and at times prior thereto, the employer failed to document the King valve was visibly labeled and was accessible in accordance with Recognized and Generally Accepted Good Engineering Practices (RAGAGEP), such as but not limited to, the guidance set forth International Institute of Ammonia Refrigeration IIAR Bulletin 109.
f) On or about November 8; 2018, and at times prior thereto, the employer failed to document the machinery room as a hazardous (Classified) Location (of not less than a Class 1, Division 2) in accordance with Recognized and Generally Accepted Good Engineering Practices (RAGAGEP); such as but not limited to, IIAR2, 2014, Section 6.8, The employer uses over 10,000 pounds of the anhydrous ammonia for refrigerant for the freezers and to cool the processing floor.
g) On or about November 8, 2018, and at times prior thereto, the employer failed to document that there was a least bne calibrated and operating anhydrous ammonia detector in the machinery room that would activate an alarm and mechanical ventilation in accordance with RAGAGEP, such as, but not limited to IIAR 2, 2014,. Section 6.13 and 6.14 Standard for Safety Design of Closed Circuit Ammonia Refrigeration Systems.
h) On or about November 8, 2018, and at times prior thereto, the employer failed to document there were working visual and audible alarms inside the engine room and outside each entrance to the: engine room in accordance with Recognized and Generally Accepted Good Engineering Practices (RAGAGEP), such as but not limited to, the guidance set forth in IIAR 2, 2014, Section 6.13 and Section 17. Equipment, Design; and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems.
i) On or about November 8, 2018, ·and at times prior thereto, the employer failed to document that in the event of a release the system was being monitored with a continual oversight to a responsible party in accordance with Recognized and Generally Accepted Good Engineering Practices (RAGAGEP), such as but not limited to, the guidance set forth in IIAR 2, 2014, Section 17, Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems.
j) On or about November 8, 2018, and at times prior thereto, the employer did not document that they complied with Recognized and Generally Good Engineering Practices (RAGAGEP), such as IIAR 2, 2014, Section 6.4, Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems, when the employer failed to ensure that flammable and combustible materials such as miscellaneous wood items were not stored in the machinery room.
k) On or about November 8, 2018, and at the time prior thereto, the employer did not ensure material and energy balances were provided for the process. The employer uses over 10,000 pounds of the anhydrous ammonia for refrigerant for the freezers and to cool the processing floor. One onsite document stated the system contained about 12,788 pounds of anhydrous ammonia, the employer stated the system contained about 9,867 pounds of anhydrous ammonia.
l) On or about November 8, 2018, and times prior thereto, the employer did not develop a process flow diagram for the process. The employer uses over 10,000 pounds of the anhydrous ammonia for refrigerant for the freezers and to cool the processing floor.
Citation 2 Item 2
Type of violation: Willful; $132,598
29 CFR 1910.119(e)(1): The employer did not perform an initial process hazard analysis (hazard evaluation) on processes covered by 29 CFR 1910.119:
On or about November 8, 2018, the employer failed to perform an initial process hazard analysis in order to identify, evaluate and control the hazards involved in the operation of the ammonia refrigeration system located at the facility. The process hazard must address the following:
– the identification of any previous incidents which had a likely potential for catastrophic consequences in the workplace;
– engineering and administrative controls applicable to the hazards and their interrelationship such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrument with alarms, and detection hardware such as anhydrous ammonia sensors);
– consequences of the failure of engineering and administrative controls;
– facility siting;
– human factors and
– a qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace.
Citation 2 Item 3
Type of Violation: Willful; $132,598
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 arid addressing at least steps for each operating phase, safe operating limits, safety and health considerations, and safety systems and their functions as outlined by this paragraph:
On or about November 8, 2018, the employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in the operation of the ammonia refrigeration system present at the facility, consistent with the process safety information and addressing at least the following elements:
– Initial startup;
– Normal operations;
– Temporary operations;
– Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner;
– Emergency Operations;
– Normal shutdown;
– Startup following a turnaround, or after an emergency shutdown;
– Operating limits;
– Consequences of deviation;
– Steps required to correct or avoid deviation;
– Safety and health considerations.
Citation 2 Item 4
Type of Violation: Willful; $132,598
29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of the process equipment:
On or about November 8, 2018, at and times prior thereto, the employer did not ensure that written procedures to maintain.the integrity of the process equipment were put in place. The employer uses over 10,000 pounds of anhydrous ammonia for refrigerant for the freezers and cooling the processing floor.
The employer did not establish and implement written procedures to maintain the mechanical integrity of equipment such as, but not limited to:
1. Vessels
2. Piping
3. Compressors and pumps
4. Pressure relief devices
5. Process instrumentation and controls including, but not limited to, monitoring devices and sensors, alarms, interlocks, emergency shutdown systems
6. Critical equipment to ensure that proper spare parts and/or spare equipment were available
7. Air Handling Equipment
8. High and Low pressure/temperature receiver recirculators
9. Autopurger
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