OSHA found an Idaho frozen food manufacturer failed to safeguard employees and was unprepared to respond to a release of 1,300 lbs. of anhydrous ammonia on Dec. 1, 2015. While no one suffered an injury in the December incident, other major ammonia releases at the facility have hospitalized employees in the past. In its review of the latest incident, OSHA found the company lacked adequate emergency response program and training, and failed to equip employees with protective clothing and respirators. OSHA issued 19 serious and two (2) willful citations following the hazardous release. OSHA found numerous violations during its inspection, including:
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 1a
Type of Violation: Serious; $7,000 29 CFR 1910.38(f)(1): The employer did not review the emergency action plan with each employee covered by the plan when the employee was assigned initially to a job:
29 CFR 1910.38(f)(1): The employer did not review the emergency action plan with each employee covered by the plan when the employee was assigned initially to a job:
a) On or about December 1, 2015, in the workplace: The employer did not review employee responsibilities under Section 15.1 of the emergency action plan with Maintenance employees with regards to ammonia releases. Citation 1 Item 1b
Citation 1 Item 1b
Type of Violation: Serious; GROUPED 29 CFR 1910.38(f)(2): The employer did not review the emergency action plan with each employee covered by the plan when the employee’s responsibilities under the plan change.
29 CFR 1910.38(f)(2): The employer did not review the emergency action plan with each employee covered by the plan when the employee’s responsibilities under the plan change.
a) On or about December 1, 2015, in the workplace: The employer did not review employee responsibilities during an ammonia release under Section 15.1 of the emergency action plan with employees that have been re-assigned to the maintenance department.
Citation 1 Item 2
Type of Violation: Serious; $7,000 29 CFR 1910.120(q)(1): The employer did not implement an emergency response plan to handle anticipated emergencies prior to commencement of emergency response operations:
29 CFR 1910.120(q)(1): The employer did not implement an emergency response plan to handle anticipated emergencies prior to commencement of emergency response operations:
a) On or about December 1, 2015, or prior thereto: the facility did not implement pre-emergency planning and coordination with outside parties during anhydrous ammonia releases. b) On or about December 1, 2015, or prior thereto: the facility did not implement training and communication procedures during anhydrous ammonia releases. c) On or about December 1, 2015, or prior thereto: the facility did not implement emergency recognition and prevention procedures for anhydrous ammonia releases. d) On or about December 1, 2015, or prior thereto: the facility did not implement decontamination procedures during anhydrous ammonia releases. e) On or about December 1, 2015, or prior thereto: the facility did not implement critique of response and follow-up after anhydrous ammonia releases. f) On or about December 1, 2015, or prior thereto: the facility did not implement PPE and emergency equipment procedures during anhydrous ammonia releases.
b) On or about December 1, 2015, or prior thereto: the facility did not implement training and communication procedures during anhydrous ammonia releases. c) On or about December 1, 2015, or prior thereto: the facility did not implement emergency recognition and prevention procedures for anhydrous ammonia releases. d) On or about December 1, 2015, or prior thereto: the facility did not implement decontamination procedures during anhydrous ammonia releases. e) On or about December 1, 2015, or prior thereto: the facility did not implement critique of response and follow-up after anhydrous ammonia releases. f) On or about December 1, 2015, or prior thereto: the facility did not implement PPE and emergency equipment procedures during anhydrous ammonia releases.
c) On or about December 1, 2015, or prior thereto: the facility did not implement emergency recognition and prevention procedures for anhydrous ammonia releases. d) On or about December 1, 2015, or prior thereto: the facility did not implement decontamination procedures during anhydrous ammonia releases. e) On or about December 1, 2015, or prior thereto: the facility did not implement critique of response and follow-up after anhydrous ammonia releases. f) On or about December 1, 2015, or prior thereto: the facility did not implement PPE and emergency equipment procedures during anhydrous ammonia releases.
d) On or about December 1, 2015, or prior thereto: the facility did not implement decontamination procedures during anhydrous ammonia releases. e) On or about December 1, 2015, or prior thereto: the facility did not implement critique of response and follow-up after anhydrous ammonia releases. f) On or about December 1, 2015, or prior thereto: the facility did not implement PPE and emergency equipment procedures during anhydrous ammonia releases.
e) On or about December 1, 2015, or prior thereto: the facility did not implement critique of response and follow-up after anhydrous ammonia releases. f) On or about December 1, 2015, or prior thereto: the facility did not implement PPE and emergency equipment procedures during anhydrous ammonia releases.
f) On or about December 1, 2015, or prior thereto: the facility did not implement PPE and emergency equipment procedures during anhydrous ammonia releases.
Citation 1 Item 3
Type of Violation: Serious; $7,000 29 CFR 1910.120(q)(1O):
29 CFR 1910.120(q)(1O): Chemical-protective clothing and equipment to be used by organized and designated HAZMAT team members, or to be used by hazardous materials specialists, did not meet the requirements of paragraphs (g)(3) through (5) of this section.
a) On or about December 1, 2015, or prior thereto: The employer did not provide appropriate chemical protective gloves ammonia releases. Maintenance Tech 1 and Generalists were required to participate in ammonia related emergency responses and had not received appropriate PPE.
b) On or about December 1, 2015, or prior thereto: The employer did not provide appropriate chemical protective boots ammonia releases. Maintenance Tech 1 and Generalists were required to participate in ammonia related emergency responses and had not received appropriate PPE.
c) On or about December 1, 2015, or prior thereto: The employer did not provide appropriate chemical protective coveralls ammonia releases. Maintenance Tech 1 and Generalists were required to participate in ammonia related emergency responses and had not received appropriate PPE.
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 4a
Type of Violation: Serious; $7,000 29 CFR 1910.134(e)(1): The employer did not provide a medical evaluation to determine the employee’s ability to use a
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 is fit tested or required to use the respirator in the workplace.
a) On or about December 1, 2015, or prior thereto: Maintenance employees responded to ammonia releases with full face cartridge respirators, but were not medically evaluated. Ammonia releases have included the release of 1,300 pounds from the Line B refrigeration system. Citation I Item 4b
Citation 1 Item 4b
Type of Violation: Serious; GROUPED 29 CFR 191O.134(f)(2): The employer did not ensure that an employee using a tight-fitting facepiece respirator is fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter. a) On or about December 1, 2015, or prior thereto: Employees required to wear full face respirators for responding to ammonia releases were not fit tested. Emergency responses have included the release of 1,300 pounds of ammonia from the Line B refrigeration system.
29 CFR 191O.134(f)(2): The employer did not ensure that an employee using a tight-fitting facepiece respirator is fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter. a) On or about December 1, 2015, or prior thereto: Employees required to wear full face respirators for responding to ammonia releases were not fit tested. Emergency responses have included the release of 1,300 pounds of ammonia from the Line B refrigeration system.
a) On or about December 1, 2015, or prior thereto: Employees required to wear full face respirators for responding to ammonia releases were not fit tested. Emergency responses have included the release of 1,300 pounds of ammonia from the Line B refrigeration system.
Citation 2 Item 1
Type of Violation: Willful; $70,000 29 CFR 1910.120(q)(6): Training was not based on the duties and function to be performed by each responder of an emergency response organization. The skill and knowledge levels required for all new responders, those hired after the effective date of this standard, was not conveyed to them through training before they are permitted to take part in actual emergency operations on an incident.
29 CFR 1910.120(q)(6): Training was not based on the duties and function to be performed by each responder of an emergency response organization. The skill and knowledge levels required for all new responders, those hired after the effective date of this standard, was not conveyed to them through training before they are permitted to take part in actual emergency operations on an incident.
a) On or about December 1, 2015, or prior thereto: Maintenance employees responded to an ammonia release in the role of a Hazardous Materials Technician without proper emergency response training per 1910.120(q)(6)(iii). The response to ammonia releases is required by Dickinson Frozen Foods, Inc.
b) On or about December 1, 2015, or prior thereto: Maintenance employees responded to an ammonia release in the role of a Hazardous Materials Specialist without proper emergency response training per 1910.120(q)(6)(iv). The response to ammonia releases is required by Dickinson Frozen Foods, Inc.
c) On or about December 1, 2015, or prior thereto: Maintenance employees responded to an ammonia release in the role of an Incident Commander without proper emergency response training per 1910.120(q)(6)(v). The response to ammonia releases is required by the facility.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 2 Item 2a
Type of Violation: Willful; $70,000 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:
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:
a) On or about December 1, 2015, or prior thereto, in the Line B Compressor Room: The Tech 2 was exposed to unknown levels of ammonia while wearing a full face cartridge respirator when responding to 1,300 lbs. ammonia leak. Ammonia level measurements were not taken by employees during the response.
b) On or about December 1, 2015, or prior thereto, in the Line B Compressor Room: The Tech 1 was exposed to unknown levels of ammonia while wearing a full face cartridge respirator when responding to 1,300 lbs. ammonia leak. Ammonia level measurements were not taken by employees during the response. c) On or about December 1, 2015, or prior thereto, in the Line B Compressor Room: The Generalist was exposed to unknown levels of ammonia while wearing a full face cartridge respirator when responding to
c) On or about December 1, 2015, or prior thereto, in the Line B Compressor Room: The Generalist was exposed to unknown levels of ammonia while wearing a full face cartridge respirator when responding to a 1,300 lbs. ammonia leak. Ammonia level measurements were not taken by employees during the response. d) On or about December 1, 2015, or prior thereto, in the Line B compressor Room: The Maintenance Manager was exposed to unknown levels of ammonia while wearing a full face cartridge respirator when responding to
d) On or about December 1, 2015, or prior thereto, in the Line B compressor Room: The Maintenance Manager was exposed to unknown levels of ammonia while wearing a full face cartridge respirator when responding to a 1,300 lbs. ammonia leak. Ammonia level measurements were not taken by employees during the response.
Citation 2 Item 2b
Type of Violation: Willful; $70,000
29 CFR 1910.120(q)(3)(iv): Employees engaged in emergency response and exposed to hazardous substances presenting an inhalation hazard or potential inhalation hazard did not wear positive pressure self-contained breathing apparatus while engaged in emergency response, until such time that the individual in charge of the JCS determined through the use of air monitoring that a decreased level of respiratory protection did not result in hazardous exposures to employees:
a) On or about December 1, 2015, or prior thereto, in the Line B Compressor Room: The Tech 2 was exposed to unknown levels of ammonia while wearing a full face cartridge respirator when responding to 1,300 lbs. ammonia leak. Ammonia level measurements were not taken by employees during the response. b) On or about December 1, 2015, or prior thereto, in the Line B Compressor Room: The Tech 1 was exposed to unknown levels of ammonia while wearing a full face cartridge respirator when responding to
b) On or about December 1, 2015, or prior thereto, in the Line B Compressor Room: The Tech 1 was exposed to unknown levels of ammonia while wearing a full face cartridge respirator when responding to a 1,300 lbs. ammonia leak. Ammonia level measurements were not taken by employees during the response. c) On or about December 1, 2015, or prior thereto, in the Line B Compressor Room: The Generalist was exposed to unknown levels of ammonia while wearing a full face cartridge respirator when responding to
c) On or about December 1, 2015, or prior thereto, in the Line B Compressor Room: The Generalist was exposed to unknown levels of ammonia while wearing a full face cartridge respirator when responding to a 1,300 lbs. ammonia leak. Ammonia level measurements were not taken by employees during the response.
d) On or about December 1, 2015, or prior thereto, in the Line B Compressor Room: The Maintenance Manager was exposed to unknown levels of ammonia while wearing a full face cartridge respirator when responding to 1,300 lbs. ammonia leak. Ammonia level measurements were not taken by employees during the response.
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