OSHA Inspection: AMERICAN SEAFOODS INTERNATIONAL, LLC

Issued

Jul 7, 2010

Abate by

Aug 23, 2010

Penalty

Initial $7,000 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i)(A):  Process safety information pertaining to the
technology of the
process did not include a block flow diagram or simplified process flow
diagram:
Facility: The employer failed to include all main flow streams of the
ammonia refrigeration
system in the block flow diagram:
a)flow of ammonia from Machine #11 high pressure receiver to the Machine
#10 vertical
flash accumulator to the Machine #9 low pressure receiver/processing pump
package;
b)flow of ammonia from Machine #12 low pressure receiver/storage pump
package to
evaporators in the old and new cold storage freezers, north and south
coolers, bread &
batter cooler, Chester Jensen falling film chiller, and office air
conditioning chiller; and
c)flow of ammonia from the condensers Machine #12 low pressure
receiver/storage pump
package.

Issued

Jul 7, 2010

Abate by

Dec 31, 2010

Penalty

Initial $7,000 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D):  Process safety information pertaining to the
equipment in the
process did not include the relief system design and design basis:
Facility: The employer failed to document the relief system design and
design basis for the
ammonia refrigeration system, which included compressors #1, #2, #3, and
#4; machine #9 low
pressure receiver and oil pot; machine #10 vertical flash accumulator,
machine #11 high pressure
receiver, and machine #12 low pressure receiver and oil pot.

Issued

Jul 7, 2010

Abate by

Oct 4, 2010

Penalty

Initial $7,000 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(E):  Process safety information pertaining to the
equipment in the
process did not include the ventilation system design:
Refrigeration Room: The employer failed to have documentation on the
design of the exhaust
fans.st

Issued

Jul 7, 2010

Abate by

Oct 4, 2010

Penalty

Initial $7,000 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii):  The employer did not document that the
equipment in the process
complied with recognized and generally accepted good engineering practices:
The employer failed to document that equipment complied with good
engineering practices:
a)At the facility, not all ammonia refrigeration piping and system
components were
identified/marked/labeled according to recognized and generally accepted
good
engineering practices, such as, IIAR Bulletin, 114-1991, Section 4.0 for
the following
but not limited to, machine #12 low pressure receiver (LPR) and piping,
machine #9
LPR and piping, machine #10 vertical accumulator and piping, machine #11
high
pressure receiver (HPR) and piping, piping associated with evaporators in
Cold Storage
Freezer #1, piping on the roof for condensers, and piping on the roof for
Spiral Freezer
#4.
b)The electrical equipment in the Refrigeration Room was not rated for a
hazardous
atmosphere and the continuously run exhaust fans did not have an alarm
system to
indicate fan failure as according to recognized and generally accepted
good engineering
practices such as ANSI/IIAR, 2-1999, Section 6.2.1.2.

Issued

Jul 7, 2010

Abate by

Dec 31, 2010

Penalty

Initial $7,000 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(g)(2):  The employer did not provide refressher training
at least every three
years to the each employee involved in operating a process to assure that
the
employee
understands and adheres to the current operating procedures of the process:
Facility: The employer failed to provide refresher training on the
operating procedures at least
every three years since 2002, for employees operating and/or working on
the ammonia
refrigeration system.ration

Issued

Jul 7, 2010

Abate by

Aug 23, 2010

Penalty

Initial $7,000 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(g)(3):  The employer did not prepare a record which
contained the identity
of the employee, the date of training, and the means used to verify that
the employee understood
the training:
Facility: The employer failed to have records which demonstrate that
operating employees
received and understood training that is required including training on
operating procedures of
the ammonia refrigeration system.ration

Issued

Jul 7, 2010

Abate by

Aug 23, 2010

Penalty

Initial $7,000 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(k)(1):  The employer did not issue a hot work permit for
work operations
conducted on or near a covered process:
Facility, Hydraulic Room, January 9, 2010: The employer did not ensure
that a hot work permit
for welding operations on an ammonia gas line was issued.

Issued

Jul 7, 2010

Abate by

Dec 31, 2010

Penalty

Initial $7,000 · Current $5,000 Reduced

General-duty citation text

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:
The employer failed to establish and implement written procedures to
manage changes in the
ammonia refrigeration system such as:
1.Installation of  Spiral Freezer #4/LVS Spiral Freezer on November 9,
2007 and
associated piping;
2.Addition of an oil pot to Spiral Freezer #4 around March 2008;
3.Replacement of three condensers of different make and model from 2004 -
2008.

Issued

Jul 7, 2010

Abate by

Oct 4, 2010

Penalty

Initial $7,000 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(l)(4):  A change covered by 29 CFR 1910.119(l) resulted in
a change in the
process safety information required by 29 CFR 1910.119(d) and the process
information was not
updated:
The employer failed to update process safety information when there was a
change in the system
- the piping & instrumentation diagrams were not updated with the
following:
1.Installation of Spiral Freezer #4/LVS Spiral Freezer on November 9, 2007
and associated
piping;
2.Addition of an oil pot to Spiral Freezer #4 around March 2008;
3.Replacement of three condensers of different make and model from 2004 -
2008.

Issued

Jul 7, 2010

Abate by

Oct 4, 2010

Penalty

Initial $7,000 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(m)(1):  The employer did not investigate each incident
which resulted in, or
could reasonably have resulted in, a catastrophic release of a highly
hazardous chemical in the
workplace:
Facility: The employer failed to conduct an incident investigation for an
ammonia leak in the
Refrigeration Room on a thermostatic expansion valve on compressor #4 that
occurred in
January 2008.ry

Issued

Jul 7, 2010

Abate by

Aug 23, 2010

Penalty

Initial $7,000 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(m)(4)(v):  The report prepared at the conclusion of the
investigation of an
incident which resulted in, or could have reseasonably resulted in a
catastrophic release of highly
hazardous chemical in the workplace, did not include any recommendations
resulting
from the
investigation team:
Facility:  The employer failed to include recommendations in the incident
investigation report
for the release that occured on August 11, 2009.t

Issued

Jul 7, 2010

Abate by

Aug 1, 2011

Penalty

Initial $7,000 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.119(o)(1):  The employer did not certify that they had
evaluated compliance with
the provisions of 29 CFR 1910.119 at least every three years to verify
that the procedures and
practices developed under this standard were adequate and are being
followed:
Facility: The employer did not certify or evaluate the process safety
management program every
three years since establishing it in 2002.lishing

Issued

Jul 7, 2010

Abate by

Aug 1, 2011

Penalty

Initial $70,000 · Current $57,500 Reduced

General-duty citation text

29 CFR 1910.119(e)(1):  The process hazard analysis was not appropriate to
the complexity of
the process and did not identify, evaluate, and address the control of the
hazards involved in the
process:
The employer did not perform a process hazard analysis (PHA) that
identified, evaluated and
controlled the hazards of the process in that:
a)The PHAs for the compressors, condensers, and autopurger did not list
controls or
recommendations for dealing with the hazards identified.
b)No PHAs were performed for the following pieces of equipment in the
refrigeration
system:
1. Machine #12 low pressure receiver (LPR) and associated oil pot and
pumps,
2. Machine #9 LPR and associated oil pot and pumps,
3. Machine #10 vertical accumulator,
4. Machine #11 high pressure receiver (HPR),
5. Dump tank,
6. Evaporators.

Issued

Jul 7, 2010

Abate by

Aug 1, 2011

General-duty citation text

29 CFR 1910.119(e)(3)(i):  The process hazard analysis (PHA) did not
address the hazards of
the process:
The PHA did not address:
a)hazards associated with a power failure;
b)ammonia leaks due to corrosion of ammonia piping;
c)hazards associated with not marking piping and equipment of the ammonia
refrigeration
system components;
d)hazards associated with the loading operations, in which ammonia is
added to the
ammonia refrigeration system.ration

Issued

Jul 7, 2010

Abate by

Aug 1, 2011

General-duty citation text

29 CFR 1910.119(e)(3)(ii):  The process hazard analysis did not identify
any previous incident
which had a likely potential for catastrophic consequences in the
workplace:
Facility: Since January 2001, the employer failed to address a previous
serious ammonia release
which occurred in the refrigeration room from a low-pressure ammonia
supply pump
malfunction,  in the PHA.

Issued

Jul 7, 2010

Abate by

Aug 1, 2011

General-duty citation text

29 CFR 1910.119(e)(3)(iii):  The process hazard analysis did not address
the engineering and
administrative controls applicable to the hazards and their
interrelationship:
The employer failed to address engineering and administrative controls in
the PHA such as:
a)the ammonia detection system;
b)continuously operating exhaust fans in refrigeration room in the absence
of Class 1,
Division II classification;
c)emergency isolation valves such as King Valves;
d)the mechanical integrity procedures for equipment, such as, but not
limited to low and
high pressure receiver, vertical accumulator, evaporators, dump tanks and
piping.tors,

Issued

Jul 7, 2010

Abate by

Aug 1, 2011

General-duty citation text

29 CFR 1910.119(e)(3)(iv):  The process hazard analysis did not address
the consequences of
failure of engineering and administrative controls:
Facility: The employer failed to address consequences of failure of
engineering and
administrative controls in the PHA such as the ammonia detection system,
continuously operated
exhaust fans in refrigeration room, mechanical integrity program and King
valves.

Issued

Jul 7, 2010

Abate by

Aug 1, 2011

General-duty citation text

29 CFR 1910.119(e)(3)(vi):  The process hazard analysis did not address
human factors:
Facility: The employer failed to address human factors as they relate to
marking of the
ammonia piping or equipment in the PHA.

Issued

Jul 7, 2010

Abate by

Aug 1, 2011

General-duty citation text

29 CFR 1910.119(e)(6):  The employer did not ensure after the initial
process hazard analysis
that the process hazard analysis was updated and revalidated at least
every five (5) years by a
team meeting the requirements of 29 CFR 1910.119(e)(4):
Facility: Since 2002, the employer did not update the PHA every five years
with a team.

Issued

Jul 7, 2010

Abate by

Aug 1, 2011

Penalty

Initial $55,000

Issued

Jul 7, 2010

Abate by

Aug 1, 2011

Issued

Jul 7, 2010

Abate by

Aug 1, 2011

Issued

Jul 7, 2010

Abate by

Aug 1, 2011

Issued

Jul 7, 2010

Abate by

Nov 15, 2010

General-duty citation text

29 CFR 1910.119(f)(4):  The employer did not develop and implement safe
work practices for
employees and contractor employees to provide for the control of hazards
during operations such
as lockout/tagout; confined space entry; opening process equipment or
piping; and control over
entrance into a facility by maintenance, contractor, laboratory, or other
support personnel:
Facility: The employer did not develop and implement safe work practices
for line breaking
operations.

Issued

Jul 7, 2010

Abate by

Nov 15, 2010

General-duty citation text

29 CFR 1910.119(f)(4):  The employer did not develop and implement safe
work practices for
employees and contractor employees to provide for the control of hazards
during operations such
as lockout/tagout; confined space entry; opening process equipment or
piping; and control over
entrance into a facility by maintenance, contractor, laboratory, or other
support personnel:
Facility: The employer did not develop and implement safe work practices
for line breaking
operations.

Issued

Jul 7, 2010

Abate by

Dec 31, 2010

Penalty

Initial $70,000 · Current $57,500 Reduced

General-duty citation text

29 CFR 1910.119(j)(2):  The employer did not establish and implement
written procedures to
maintain the on-going mechanical integrity of process equipment:
a)Facility:  Employer did not have written procedures mechanical integrity
(MI) procedures
on current maintenance practices - daily, monthly, and yearly maintenance
on the
ammonia refrigeration system including, but not limited to:
1. #9 Low Pressure Receiver
2. #10 Vertical Accumulator
3. #11 High Pressure Receiver
4. #12 Low Pressure Receiver
5. Dump tank
6. Auto purger
7. Ammonia piping including liquid lines, gas lines, thermosyphon suction
and return,
high stage discharge, relief valve headers
8. Instruments and controls such as level indicators and ammonia vapor
detectors
9. Valves such as King valves, check valves, solenoid valves
b)Facility: Employer did not develop and implement MI procedures for the
ammonia
refrigeration system including, but not limited to, ammonia supply pumps,
oil pots,
compressors, condensers, and evaporators.

Issued

Jul 7, 2010

Abate by

Dec 31, 2010

General-duty citation text

29 CFR 1910.119(j)(4)(i):  Inspections and tests were not performed on
process equipment to
maintain its mechanical integrity:
Facility: Employer did not conduct inspections and tests on pressure
vessels, pipes, controls and
valves, such as, but not limited to:
1. #9 Low Pressure Receiver
2. #10 Vertical Accumulator
3. #11 High Pressure Receiver
4. #12 Low Pressure Receiver
5. Dump tank
6. Auto purger
7. Ammonia piping including liquid lines, gas lines, thermosyphon suction
and return,
high stage discharge, relief valve headers
8. Instruments and controls such as level indicators and ammonia vapor
detectors
9. Valves such as King valves, check valves, and solenoid valves
The inspections and tests should be done according to recognized and
generally accepted good
engineering practices as stated in Citation 2 Item 3c.

Issued

Jul 7, 2010

Abate by

Aug 1, 2011

General-duty citation text

29 CFR 1910.119(j)(4)(ii):  Inspections and testing procedures performed
on process equipment
to maintain its mechanical integrity, did not follow recognized and
generally accepted good
engineering practices:
Facility: Employer did not follow good engineering practices for the
following inspections and
tests:
a) The mechanical integrity program did not include procedures for the
inspection and testing
of pressure vessels and heat exchangers that followed good engineering
practices.  Good
engineering practices for the inspection and testing of pressure vessels
and heat exchangers
include:
1. Weekly detailed inspection of external surface or of the insulation
applied to the
external surface performed by system operating personnel when equipment is
operational.
2. Annual inspection of external surface or of the insulation applied to
the external
surface performed by persons other than normal system operators.
3. Weekly or at regular intervals drain oil from all oil drain points.
4. Annually test automatic controls such as head pressure controls for
correct operation.
5. Full independent inspection by competent person every 5 years on annual
inspection
requirements.  When appropriate, perform additional techniques to check
for cracks and
flaws and thickness measurements by using dyes, ultrasonic measurements,
and
radiography.
b) The mechanical integrity program did not include procedures for the
inspection
and testing
of ammonia supply pumps that followed good engineering practices.  Good
engineering practices
for the inspection and testing of ammonia supply pumps include:
1. Isolate, vent, and defrost ammonia pumps at least monthly.
c) The mechanical integrity program did not include procedures for the
inspection and testing
of shut-off valves and control valves that followed good engineering
practices.  Good
engineering practices for the inspection and testing of shut-off valves
and control valves include:
1. Visually inspect shut-off valves on machinery when operational
inspection of such
machinery is conducted.
2. Every 6 months, inspect condition of stem and gland seals on shut-off
valves with
exposed stems and clean and re-grease stem.
3. Externally inspect shut-off valves annually.
4. Test shut-off valves every 5 years for function.5. Annually test
automatic control valves for correct function.
d) The mechanical integrity program did not include procedures for the
inspection and testing
of pressure relief devices that followed good engineering practices.  Good
engineering practices
for the inspection and testing of pressure relief devices include:
1. Visually inspect pressure relief devices annually for corrosion or
accumulation of scale
and for leaks.
2. Annually inspect vent lines.
e) The mechanical integrity program did not include procedures for the
inspection and testing
of sensing devices such as pressure, temperature, or level operated
switches or controls, pressure
gauges, ammonia vapor detectors that followed good engineering practices.
Good engineering
practices for the inspection and testing of sensing devices include:
1. Inspect, test, and calibrate sensing devices such as pressure,
temperature, or level
operated switches or controls, pressure gauges, ammonia vapor detectors as
per
manufacturer's recommendations.
2. Annually test safety cutouts.
f) The mechanical integrity program did not include procedures for the
inspection and testing
of piping that followed good engineering practices.  Good engineering
practices for the
inspection and testing of piping include:
1. Annually inspect uninsulated piping.
2. Annually conduct external inspection of insulated piping and supports.

Issued

Jul 7, 2010

Abate by

Dec 31, 2010

General-duty citation text

29 CFR 1910.119(j)(4)(iii):  The frequency of inspections and tests of
process equipment to
maintain its mechanical integrity, was not consistent with applicable
manufacturers'
recommendations and good engineering practices, or more frequently
determined to be necessary
by prior operating experience:
a)Facility: The employer did not conduct inspections and tests on
compressors to the
frequency consistent with good engineering practices.  Good engineering
practices for
the compressors include:
1. Annually inspected inspect drive alignment, foundation bolts, and drive
shaft
end float on compressors.
2. Annually test compressor protection devices and cutouts, such as such
as high
pressure and low pressure cutouts, oil pressure differential switches, and
oil
temperature cutouts
b) Facility: The employer did not conduct inspections and tests of
evaporative condensers
to the frequency consistent with good engineering practices.  Good
engineering practices
for the evaporative condensers include:
1. Clean pan strainer and check bleed-off valve for proper operation
weekly.
2. Clean and flush pan, check operating level in pan, and adjust float
valve
monthly.

Issued

Jul 7, 2010

Abate by

Aug 1, 2011

General-duty citation text

29 CFR 1910.119(j)(4)(iv):  The employer did not document each inspection
and test that has
been performed on process equipment.  The documentation of the inspection
or test that been
performed on process equipment to maintain its mechanical integrity did
not identify the date
of the inspection or test, the serial number or other identifier of the
equipment on which the
inspection or test was performed, a description of the inspection or test,
and the results of the
inspection or test:
a)Facility: The employer did not ensure that documentation of inspections
such as but not
limited to daily inspections of compressors, ammonia pumps, and condensers
included
name of person who performed inspection or test, equipment identification,
description
of the test and results of the inspection or test.
b)Facility: Documentation of inspection and tests performed by a
contractor did not include
the date of the inspection or test, the name of the person who performed
the inspection
or test, the serial number or other identifier of the equipment, and
description of the
inspection or test performed and results of the inspection or test.