OSHA initiated the October 2015 inspection following a report of an ammonia release (apparently during a manual purge of NH3) at the warehousing and logistics company. The agency cited the company for nine serious violations, six for process safety management standards violations, two for not fit testing or providing a medical evaluation of employees before they could wear respirators, and one serious violation was issued for not having a functioning emergency safety eyewash station. Here is a breakdown of all the citations:
Citation 1 Item 1
Type of Violation: Serious; $3,000
29 CFR 1910.119(d)(3)(i)(B): The employer’s piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process:
This violation was most recently observed on or about October 15, 2015, the employer did not ensure Process Safety Information (PSI) such as Piping and Instrumentation Diagrams (P&ID) were current, complete and/or accurate, such as, but not limited to, auto-purge.
Citation 1 Item 2
Type of Violation: Serious; $7,000
29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices:
This violation was most recently observed on or about October 15, 2015 in the Ammonia Refrigeration Process when the engine room access doors leading to the dock area were not equipped with tight-fitting seal as stipulated in RAGAGEP (Recognized and Generally Accepted Engineering Practice) ANSI/ASHREA Standard 15-2013 section 8.12 in locations including, but not limited to: a. Double doors leading to the docking area. b. Single door leading to the maintenance/technician staging area.
Citation 1 Item 3
Type of Violation: Serious; $7,000
29 CFR 1910.119(e)(1): The process hazard analysis was not appropriate to the complexity of the process:
Employer PHA (Process Hazard Analysis) was incomplete/inadequate in that it did not address or identify the need for a manual purge in case that the mechanical auto-purge instrument failed to operate, exposing employees to anhydrous ammonia.
NOTE: there was NO item 4 in this citation
Citation 1 Item 5
Type ofViolation: 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 were taken to assure safe operation:
This violation was most recently observed on or about October 14, 2015, in the engine room, when the employer failed to ensure the insulation on process piping, such as, but not limited to, V-4 in the ammonia engine room was repaired and sealed to prevent condensation and corrosion.
Citation 1 Item 6
Type of Violation: Serious; $7,000
29 CFR 1910.119(l)(5): When a change covered by this paragraph resulted in a change in the operating procedures or practices required by paragraph (f) of this section, such procedures or practices were not updated accordingly:
At this location, the employer failed to conduct a Management of Change (MOC) when going conducting a manual purge rather than a continuous standby auto-purge of the process.
Citation 1 Item 7
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 respirator before the employee was fit tested or required to use the respirator in the workplace:
On October 14, 2015, employees conducted a manual release of anhydrous ammonia on an ammonia refrigeration unit and were not provided with a medical evaluation.
Citation 1 Item 8
Type of Violation: Serious; $7,000
29 CFR 1910.134(f)(2): Employee(s) using tight-fitting facepiece respirators were not fit-tested prior to initial use of the respirator:
On October 14, 2015, employees conducted a manual release to the atmosphere unit and had not been fit-tested.
Citation 1 Item 9
Type of Violation: Serious; $6,000
29 CFR 1910.151(c): Where employees were exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use:
At this job site, employees working with anhydrous ammonia in the engine room were not provided with a functioning emergency safety shower, exposing employees to corrosive chemicals.
CLICK HERE for the Citations
NOTE: I check the NRC database for any reported releases associated with this facility and found none.