OSHA Inspection: ED MINIAT INC.

Issued

Oct 3, 1990

Abate by

Feb 4, 1991

Penalty

Initial $640 · Current $480 Reduced

General-duty citation text

SECTION 5(A)(1)OF THE OCCUPATIONAL SAFETY AND HEALTH ACT OF 1970: THE
EMPLOYER DID NOT FURNISH EMPLOYMENT AND A PLACE OF EMPLOYMENT WHICH WERE
FREE FROM RECOGNIZED HAZARDS THAT WERE CAUSING OR LIKELY TO CAUSE DEATH
OR SERIOUS PHYSICAL HARM TO EMPLOYEES IN THAT EMPLOYEES WERE EXPOSED TO
POTENTIAL AMMONIA INHALATION AND EXPLOSION HAZARDS FROM THE AMMONIA
REFRIGERATION SYSTEM.
A) THE EMPLOYER DID NOT ESTABLISH OR IMPLEMENT A COMPREHENSIVE SYSTEM
SAFETY EVALUATION FOR PREVENTION OF AMMONIA LEAKS AND EXPLOSIONS.
THIS POTENTIALLY EXPOSES EMPLOYEES TO AMMONIA HAZARDS SUCH AS EYE,
SKIN AND RESPIRATORY IRRITATION, PULMONARY EDEMA AND EXPLOSIONS.
AMONG OTHER METHODS, THE FOLLOWING ARE FEASIBLE AND ACCEPTABLE ABATEMENT
METHODS TO CORRECT THIS HAZARD:
1) CONDUCT A COMPREHENSIVE HAZARD ANALYSIS OF THE AMMONIA SYSTEM WHICH
WOULD IDENTIFY POTENTIAL SYSTEM PROBLEMS WHICH COULD LEAD TO AN
EMERGENCY OCCURRENCE.
THE HAZARD ANALYSIS COULD INCLUDE METHODS SUCH AS, BUT NOT LIMITED TO,
PRELIMINARY HAZARDS ANALYSIS (PHA); FAILURE MODE AND EFFECT ANALYSIS
(FMEA); FAULT TREE ANALYSIS (FTA); AND TECHNIQUE FOR HUMAN ERROR RATE
PREDICTION (THERP).
2) EXPAND THE EXISTING PREVENTATIVE MAINTENANCE PROGRAM TO INCLUDE THE
INTERVALS FOR INSPECTION AND TESTING OF ALL CRITICAL PROCESS SAFETY
DEVICES AND OTHER COMPONENTS OF THE AMMONIA SYSTEM AND THE EMERGENCY
SYSTEMS SUCH AS, BUT NOT LIMITED TO, OIL, FILTERS, COMPRESSOR, SAFETY
CONTROLS, CONTROL VALVES, ISOLATING VALVES, ELECTRICAL CONTROL
VALVES, OIL DRAINS, EXPANSION VALVES, PRESSURE GAUGES, TEMPERATURE
GUAGES, SIGHT GLASSES, FLOAT CONTROLS, REFRIGERANT PUMPS, SAFETY
EQUIPMENT (RESPIRATORS, EMERGENCY SHOWER, EYE WASH STATION, EMERGENCY
LIGHTING), PIPES AND VESSELS.
3) ESTABLISH WRITTEN TEST PROCEDURES WHICH EXPLAIN HOW THE PROCESS
DEVICES ARE TO BE TESTED.
4) PERFORM FUNCTION TESTS ON CRITICAL PROCESS DEVICES AFTER INITIAL
INSTALLATION AND/OR REPAIR TO ASSURE THEY FUNCTION PROPERLY BEFORE
RETURNING THE PROCESS UNTI TO NORMAL OPERATIONS.
5) MAINTAIN PERMANENTS RECORDS OF THE FOLLOWING INFORMATION AIR
MONITORING RESULTS, INSPECTION RESULTS, CORRECTIVE ACTIONS (REPAIRS,
CHANGES OR ADJUSTMENTS), TESTING RESULTS, PREVENTATIVE MAINTENANCE
ACTIVITIES, PRESSURES, TEMPERATURES, OPERATING HOURS OF THE
COMPRESSOR, OIL LEVELS AND AMOUNTS OF THE AMMONIA, OIL OR OTHER
ADDITIVES PUT IN THE SYSTEM. RECORDKEEPING APPLIES TO ITEMS
PERFORMED ON A ROUTINE OR SCHEDULED BASIS AND FOR ITEMSPERFORMED
ON AN EMERGENCY BASIS.
6) INSTRUCT AND TRAIN MAINTENANCE EMPLOYEES IN THE FOLLOWING: HOW
CRITICAL PROCESS SAFETY DEVICES OPERATE; WHAT TO DO IF A PROCESS
DEVICE FAILS OR IF IT IS OUT OF SERVICE; PROPER INSPECTION AND
TESTING PROCEDURES; PERSONAL PROTECTIVE EQUIPMENT POLICIES.
7) WHERE THERE IS THE POSSIBLITY OF EMPLOYEE EXPOSURE TO AMMONIA DUE TO
AN EMERGENCY, MEANS SHALL BE DEVELOPED TO ALERT POTENTIALLY AFFECTED
EMPLOYEES OF SUCH OCCURRENCES IMMEDIATELY (SUCH AS CONTINUOUS AIR
MONITORING DEVICES OR AMMONIA SYSTEM QUANTITY SENSORS FOR LEAK
DETECTION).
8) ESTABLISH NORMAL AND EMERGENCY OPERATION PROCEDURES. PERFORM AND
CRITIQUE AN ADEQUATE NUMBER OF "MOCK DRILLS" TO INCLUDE POTENTIAL
EMERGENCY SCENARIOS AND TO INCLUDE EMPLOYEES ON ALL SHIFTS.
9) INCLUDE AIR MONITORING DEVICES IN THE PREVENTATIVE MAINTENANCE
PROGRAM.
10) IMPLEMENT A WRITTEN FORMAL PROCEDURE FOR DETERMINING WHEN
RESPIRATORY PROTECTION AND OTHER PERSONAL PROTECTIVE EQUIPMENT SHALL
BE WORN BY MAINTENANCE EMPLOYEES.
11) ENSURE NAME PLATES ON ALL AMMONIA VESSELS AND HEAT EXCHANGERS
CONTAIN THE FOLLOWING INFORMATION:
A) MANUFACTURE'S NAME;
B) MANUFACTURE'S SERIAL NUMBER;
C) NATIONAL BOARD NUMBER;
D) ASME STAMP CERTIFICATION;
E) MAXIMUM ALLOWABLE WORKING PRESSURE; AND
F) TEMPERATURE LIMITATIONS, IF REQUIRED.
12) REPLACE ALL CAP VALVES WITH VALVES WHICH ARE CAPABLE OF BEING
CHAINED AND LOCKED-OFF.
13) VENTILATE ALL SAFETY RELIEF VALVES (SRV'S) TO DIFFUSERS, FLARES TO
ATMOSPHERE OR TO PROPERLY RELIEVED LOW PRESSURE (SUCTION) SIDE OF
THE SYSTEM.
14) VENTILATE THE OIL DRAINING OPERATION OF COMPRESSOR ROOM AND COOK
RESERVIORS OUTSIDE OF THE BUILDING.

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Penalty

Initial $420 · Current $315 Reduced

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Penalty

Initial $350 · Current $263 Reduced

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Issued

Oct 3, 1990

Abate by

Nov 19, 1990

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Issued

Oct 3, 1990

Abate by

Oct 18, 1990

Penalty

Initial $280 · Current $210 Reduced

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Penalty

Initial $280 · Current $210 Reduced

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Penalty

Initial $210 · Current $158 Reduced

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Penalty

Initial $210 · Current $158 Reduced

Issued

Oct 3, 1990

Abate by

Nov 19, 1990

Penalty

Initial $210 · Current $156 Reduced

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Issued

Oct 3, 1990

Abate by

Nov 19, 1990

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Issued

Oct 3, 1990

Abate by

Nov 5, 1990

Issued

Oct 3, 1990

Abate by

Nov 5, 1990