The targeted inspection, which began October 2014, is part of OSHA’s National Emphasis Program on chemicals, and focuses on OSHA’s PSM standard. The pork-processing facility operates two anhydrous ammonia refrigeration systems. OSHA issued seven serious citations related to the process safety management of the ammonia refrigeration systems used in its production process. Three violations are being cited for fall, electrical and machine guarding hazards. Here is a breakdown of the citations:
PLEASE NOTE: these citations are NOT the final settlement and some are BEFORE the employer’s informal conference. They are shared as a learning tool to show what types of issues OSHA and EPA are finding in their PSM/RMP inspections. I have scrubbed all company information from these postings as this is NOT about any one company, but rather a trend of issues that continue to be found by OSHA and EPA.
Citation 1 Item 1
Type of Violation: Serious; $5,000
29 CFR 1910.24(i): The employer does not ensure the vertical clearance above the stair tread to an overhead obstruction was at least 7 feet measured from the leading edge of the tread.
The violation occurred outside of the Main Ammonia Refrigeration Room on or about October 8, 2014 and at times prior thereto. Employees were exposed to a struck-by and fall hazard when the employer failed to ensure at least a 7-foot vertical overhead clearance where pipe obstructions hindered access at the top of the stair platform to the elevated ammonia refrigeration receiver.
Citation 1 Item 2
Type of Violation: Serious; $7,000
29 CFR 1910.119(d)(3)(ii): The employer does not ensure that it documents that equipment in the process complied with recognized and generally accepted good engineering practices (RAGAGEP).
- The violation occurred in the Main Engine Room and the Valve Alley Enclosure on or about October 8, 2014 and at times prior thereto. Employees were exposed to fire, explosion, and/or inhalation hazards when the employer failed to ensure emergency mechanical ventilation system(s) was activated by an ammonia detector; OR ran continuously and provided with an alarm to detect failure or shutdown of the system in accordance with ASHRAE-15.
- The violation occurred in the Main Engine Room and the Valve Alley Enclosure on or about October 8, 2014 and at times prior thereto. Employees were exposed to fire, explosion, and/or inhalation hazards when the employer failed to ensure that emergency mechanical ventilation system(s) was on a separate electrical circuit and had a control switch immediately outside the entrance door to the machine room in accordance with ASHRAE-15 and IIAR 2.
- The violation occurred in the GCS and Main Engine Rooms on or about October 8, 2014 and at times prior thereto. Employees were exposed to fire, explosion, and/or inhalation hazards when the employer failed to ensure a safety shower and eye wash station was installed external to the machinery room exit in accordance with IIAR-2.
- The violation occurred in the GCS and Main Engine Rooms on or about October 8, 2014 and at times prior thereto. Employees were exposed to fire, explosion, and/or inhalation hazards when the employer failed to ensure the thickness of severely corroded un-insulated piping ammonia piping was in accordance IIAR 2 and IIAR 110.
Citation 1 Item 3
Type of Violation: Serious; $7,000
29 CFR 1910.119(f)(1)(iv): The employer does not ensure written procedures address the requirements for the safety systems and their functions.
The violation occurred in the Main and GCS Ammonia Refrigeration Systems on or about October 8, 2014 and at times prior thereto. Employees were exposed to fire, explosion, and/or inhalation hazards from ammonia vapors when the employer failed to ensure the written operating procedures addressed the requirements for the safety systems and their functions. Identified safety systems and functions include but not limited to:
- High Discharge Pressure Shuts Down Compressors
- High Discharge Temperature Shuts Down Compressors
- High/Low Oil Pressure Differential Shuts Down Compressors
- High Accumulator Level Shuts Down Compressors
- Low Accumulator Level Shuts Down Pumps
- Ammonia Detector Alarms and Interlock Activation Of Ventilation System( s)
- Emergency Stops Outside of Entry to Engine Room
Citation 1 Item 4
Type of Violation: Serious; $7,000
29 CFR 1910.119(f)(4): The employer does not ensure development and implementation of safe work practices for control over entrance into a facility by maintenance, contractor, laboratory, and other personnel.
a. The violation occurred in the GCS, Main, and Valve Alley enclosure/machine rooms on or about October 8, 2014 and at times prior thereto. Employees were exposed to fire, explosion, and/or inhalation hazards from ammonia vapors when the employer failed to ensure it developed and implemented written procedures for controlling access into the ammonia refrigeration facility and equipment by maintenance, contractor, production, and other personnel.
Citation 1 Item 5
Type of Violation: Serious; $7,000
29 CFR 1910.119(g)(1)(i): The employer does not ensure employees involved in operating a process are provided initial training that included emphasis on specific safety and health hazards of the process and emergency operations including shutdown and safe work practices applicable to the employees job tasks.
a. The violation occurred in the GCS and Main Ammonia Refrigeration Areas on or about October 8, 2014 and at times prior thereto. Employees were exposed to fire, explosion, and/or inhalation hazards when the employer failed to ensure initial training was provided for employees who operated ammonia refrigeration equipment that included emergency shutdown, written operating procedures, and safe work practices.
Citation 1 Item 6a
Type of Violation: Serious; $7,000
29 CPR 1910.119(j)(2): The employer does not ensure written procedures are established and implemented to maintain the on-going mechanical integrity of process equipment.
The violation occurred in the GCS and Main Ammonia Refrigeration Engine Rooms on or about October 8, 2014 and at times prior thereto. Employees were exposed to fire, explosion, and/or inhalation hazards from ammonia vapors when the employer failed to ensure detailed written procedures were established and implemented for the testing and/or inspection of safety systems. Identified safety systems include but not limited to:
- Compressor Discharge High/Low Pressure
- Compressor High/Low Oil Pressure Differential
- Compressor High Discharge Temperature
- Emergency Shutdown Systems (E-Stop)
- Emergency Ventilation Systems
- High/Low Vessel Levels
- Ammonia Detectors
- Pressure Relief Valve Vents.
Citation 1 Item 6b
Type of Violation: Serious; Grouped
29 CFR 1910.119(j)(4)(i): The employer does not ensure that inspections and tests were performed on process equipment to maintain its mechanical integrity.
The violation occurred in the GCS and Main ammonia refrigeration engine rooms on or about October 8, 2014 and at times prior thereto. Employees were exposed to fire, explosion, and/or inhalation hazards from ammonia vapors when the employer failed to ensure inspection and tests were performed on process equipment such as but not limited to:
- Machine/Engine Room Emergency Shutdown (E-Stop)
- Machine/Engine Room Emergency Ventilation Systems
- Compressor High Discharge Temperature Cut Out
- Ammonia System Shut off /King Valves
Citation 1 Item 6c
Type of Violation: Serious; Grouped
29 CFR 1910.119Q)(4)(ii): The employer does not ensure that inspection and testing procedures performed on process equipment to maintain its mechanical integrity followed recognized and generally accepted good engineering practices (RAGAGEP).
The violation occurred in the GCS and Main ammonia refrigeration engine rooms on or about October 8, 2014 and at times prior thereto. Employees were exposed to fire, explosion, and/or inhalation hazards from ammonia vapors when the employer failed to ensure testing and inspections of safety systems were conducted in accordance with RAGAGEP for safety systems such as but not limited to:
- Compressor High Discharge Pressure Cut Out
- Compressor High/Low Oil Pressure Differential Cut Out
- High/Low Accumulator Vessel Level Cut Out
- Ammonia Detectors
Citation 1 Item 7
Type of Violation: Serious; $4,000
29 CFR 1910.212(a)(5): The employer does not ensure fan guard openings on the periphery of the blades is no larger than one-half (1/2) inch.
a. The violation was observed in the Main Ammonia Refrigeration Engine Room on October 8, 2014. Employees were exposed to caught-in hazards when the employer failed to ensure the guard on the portable fan had openings smaller than one-half (1/2) inch.
Citation 1 Item 8
Type of Violation: Serious; $7,000
29 CFR 1910.303(b)(6): The employer does not ensure electrical equipment is not located in damp and damp or wet location that have a deteriorating effect on the equipment.
a. The violation occurred in the Condenser Supply Pump enclosure on or about October 8, 2014 and at times prior thereto. Employees were exposed to electrocution hazards when the employer failed to ensure electrical equipment is not located in damp and damp or wet location that have a deteriorating effect on the equipment.
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