OSHA Inspection: IHP INDUSTRIAL, INC.

Issued

Apr 6, 2006

Abate by

Apr 18, 2006

Penalty

Initial $49,000

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 fire and explosion hazards due to improper or inadequate
inspections of new
gas piping systems:
(a)Workers for multiple employers at the Triumph Foods plant in St.
Joseph, MO,
were exposed to fire and explosion hazards due to this employer's failure
to
properly inspect new natural gas piping systems prior to introducing gas
into
them.  The National Fuel Gas Code (a national consensus standard) as
published
by the American Gas Association (also incorporated as ANSI-Z223.1 and NFPA-
54) requires that new systems of gas piping be inspected prior to
introducing gas
into them to determine that there are no open fittings or ends and that
all valves
at unused outlets are closed and plugged or capped.  The specific
inspection
requirement is set forth in Section 8.2.2 of the 2006 edition of the Code
[7.2.2
in the 2002 edition].  The purpose of the requirement is to protect
against the
unintentional release of natural gas through valves or other openings once
gas is
introduced into the system.  Recognition of the hazard is evidenced by its
inclusion as a mandatory requirement of the National Fuel Gas Code, and
that
compliance with the code (referenced as ANSI-Z223.1) was stipulated as
part of
the "specification" requirements in the contractual construction documents.
On or about October 12, 2005, a natural gas explosion occurred in the
first floor
kitchen area of the Triumph Foods plant which resulted in the death of one
worker, multiple serious injuries to a number of other workers, and
substantial
property damage.  The post-explosion investigation revealed that natural
gas was
introduced into a new sub-system of gas piping without that sub-system
having
been inspected in its entirety prior to allowing gas to flow into it.  The
sub-
system started at a control valve on the east side of the uppermost roof
of the
facility, dropped down to a lower roof area (above the first floor
kitchen), and
provided gas to a rooftop air handling unit mounted on the lower roof as
well as
branching off, penetrating the roof, and extending downward into the first
floor
kitchen area where several valves and branch lines were connected as part
of the
sub-system.  The initial post-explosion inspection and investigation
conducted
jointly by various officials revealed a Nordstrom 1.5" gas control valve
to be in
its fully-open position without a threaded plug or cap installed.  The
valve was
located in the first floor kitchen area and was part of the previously
described
sub-system.
One feasible and acceptable method to correct this hazard is to establish
and
enforce a program of training, observation, supervision and communication
to
ensure compliance with the applicable inspection requirement as set forth
in the
National Fuel Gas Code.  Further, in the circumstance where gas control
valves
are not under the exclusive control of the installing contractor, the
installation of
blind flanges (blanks) at appropriate points in the piping system can
prevent theinadvertent release of natural gas into a piping sub-system
that has not been
thoroughly inspected as required by Code.
Abatement certification is required for this violation (using the
CERTIFICATION OF
CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating
that abatement is complete must be included with your certification.  This
documentation
may include, but is not limited to, evidence of the purchase or repair of
the equipment,
photographic or video evidence of abatement, or other written records.