OSHA has cited a poultry processing company $119,341 for exposing employees to hazardous chemicals. On January 27, 2019, 12 employees needed transport to nearby hospitals after a leak caused the release of 2,100 pounds of anhydrous ammonia. OSHA cited the company for failing to provide an operable alarm responsible for indicating the release of hazardous chemicals. OSHA also cited the facility for failing to:
- Equip an ammonia refrigeration system with a pressure relief device as referenced by the manufacturer’s operating manual;
- Train technicians to use an alternative over-pressure safety procedure to prevent pipes from rupturing and releasing anhydrous ammonia;
- Perform management of change procedure to determine the effects of removing safety relief devices from all condensers;
- Make available medical surveillance for response team members exposed to hazardous substances above the permissible exposure limits;
- Inspect Level B respiratory protection equipment; and
- Provide a medical evaluation to determine each employee’s ability to use a respirator.
OSHA conducted the inspection in conjunction with the Regional Emphasis Program for Poultry Processing Facilities and Process Safety Management of Highly Hazardous Chemicals National Emphasis Program. Here is a breakdown of all the citations:
Citation 1 Item 1
Type of Violation: Serious; $9,472 29
CFR 1910.29(b)(2)(i): Midrails were not installed at a height midway between the top edge of the guardrail system and the walking-working surface:
a) On or about January 30, 2019, employees accessing the upper-level walking platform where the evaporative condensers are located were exposed to fall hazards of approximately 30 feet to the ground, due to a missing midrail.
Citation 1 Item 2
Type of Violation: Serious; $13,260
29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices.
(a) On or about January 27, 2019, an ammonia refrigeration condenser was not equipped with a pressure relief device as recommended by the manufacturer’s operating manual.
Citation 1 Item 3
Type of Violation: Serious; $13,260
29 CFR 1910.119(j)(3): The employer did not train each employee involved in maintaining the ongoing integrity of process equipment in the procedures applicable to the employee’s job tasks to ensure that the employee can perform the job tasks in a safe manner:
a) On or about January 29, 2019, each ammonia refrigeration maintenance technician or operator had not been trained to use an alternative over-pressure safety procedure in lieu of a hydrostatic safety relief valve to prevent shut-in liquid ammonia filled pipes from rupturing and causing the released of 2100 pounds of Anhydrous Ammonia.
Citation 1 Item 4
Type of Violation: Serious; $13,260
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.
a) On or about January 29, 2019, at Wayne Farm’s LLC in Laurel, MS, the employer did not perform testing, and inspections on Condenser EC-6, in accordance with manufacturer recommendations, to discover and prevent corrosion or other mechanical integrity discrepancies that could cause equipment failure.
Citation 1 Item 5
Type of Violation: Serious; $13,260
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:
(a) On or about January 27, 2019, the 2014 PHA indicated that prior to 2014 all condensers were equipped with safety relief valves. At some point after 2014 relief devices were removed from all condensers without management of change (MOC) being performed to determine the effects of this change on the safety of the ammonia refrigeration system.
(b) On or about January 27, 2019, Condenser EC-6 was installed in 2015 as an upgrade to the existing ammonia refrigeration system without a MOC performed to determine the effects this change on the safety of the existing ammonia refrigeration system.
Citation 1 Item 6
Type of Violation: Serious; $13,260 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.
a) On or about January 29, 2019 the employer did not establish and implement an employee alarm system in accordance with the provisions of 29 CFR 1910.38 (d) which requires that employers use a distinctive signal for each purpose (fire, inclement weather, and the release of hazardous chemicals) and comply with the requirements of 29 CPR 1910.165.
b) On or about January 27, 2019, the alarm system to indicate inclement weather, fire and the release of hazardous chemicals was not operational due to no electrical power to the alarm system. Employees were exposed to the hazard of burns, hazardous chemical and/or to inclement weather.
Citation 1 Item 7
Type of Violation: Serious; $13,260
29 CFR 1910.120(f)(3)(i)(B): Medical examinations and consultations were not made available by the employer to each employee covered under 29 CFR 1910.120(f)(2)(i), (ii), and (iv) at least once every 12 months unless the attending physician believed a longer interval (not greater than biennially) is appropriate:
a) On or about January 29, 2019, a medical surveillance for Response Team members that are exposed to hazardous substances or health hazards at or above the permissible exposure limits was not made available.
Citation 1 Item 8
Type of Violation: Serious; $7,577
29 CFR 1910.134(g)(1)(i)(A): Respirators with tight-fitting face-pieces were worn by employees who had facial hair that came between the sealing surface of the face-piece and the face or that interfered with valve function:
a) On or about January 27, 2019, employees donned respirators with facial hair that interfered with the seal of the tight-fitting full face mask respirator. Employees were exposed to an inhalation hazard.
Citation 1 Item 9
Type of Violation: Serious; $13,260
29 CFR 1910.134(h)(2)(ii)(A): Emergency respirators were not kept accessible to the work area:
(a) The facility’s emergency response trailer located north of the safety office near the northwest side of the facility, the night of the anhydrous ammonia release the emergency response equipment was locked in a trailer and not accessible to the emergency response team members. The employees were exposed to anhydrous ammonia.
Citation 1 Item 10
Type of Violation: Serious; $7,577
29 CFR 1910.1200(e)(1): The employer did not develop, implement, and/or maintain at the workplace a written hazard communication program which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met:
(a) On or about January 27, 2019, a written hazard communication program had not been developed and implemented for employees working in and around the hazardous chemical anhydrous ammonia.
Citation 2 Item 1
Type of Violation: Other-than-Serious; $1,895
29 CFR 1904.7(b)(5): The employer did not record on the OSHA 300 Log a work-related injury or illness where the employee received medical treatment beyond first aid;
On or about January 27, 2019, four employees that were treated beyond first aid were not listed on the OSHA 300 logs.
Citation 2 Item 2
Type of Violation: Other-than-Serious; $0.00 29 CFR 1910.120(g)(5)(viii): The personal protective equipment (PPE) program did not address PPE inspection procedures prior to, during, and after use:
a) On or about January 29, 2019, the employer did not inspect before and after the use of Level B suits that were worn during the release of 2100 pounds of Anhydrous Ammonia according to the manufacturer guidelines.
Citation 2 Item 3
Type of Violation: Other-than-Serious; $0.00
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:
(a) On or about January 27, 2019, the employer did not provide a medical evaluation to determine employees ability to use a respirator. Employees were exposed to an inhalation hazard.
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