OSHA Inspection: WELCH FOODS, INC.

Issued

Aug 14, 2012

Abate by

Dec 31, 2012

Penalty

Initial $4,250 · Current $2,760 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:
a.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428; main
plant engine room -
On or about February 16, 2012 and at times prior thereto, process safety
information was not
available which identified the design and design basis for the emergency
and normal ventilation
systems in the Main Plant Engine Room.  The Process safety information for
the ventilation
system was lacking specific information, including but not limited to,
references to industry
codes and standards, specific equipment list, design specification
drawings, or similar, and
calculations showing that the emergency system design would adequately
ventilate the Engine
Room based on the amount of ammonia that could be released.

Issued

Aug 14, 2012

Abate by

Dec 31, 2012

Penalty

Initial $4,250 · Current $2,760 Reduced

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):
A.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428 - the
2011 PHA
Revalidation team did not meet the requirements of 29 CFR 1910.119(e)(4)
in that an ammonia
refrigeration system mechanic from Welch Foods, Inc. was not involved in
the revalidation
process.
B.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428 - the
2011 PHA
Revalidation for the Main Plant Engine Room was not complete and accurate
in that the
Operating Procedures and Mechanical Integrity Procedures used for the
revalidation had not been
reviewed annually, did not cover each step for operation, and the
procedures were missing
information including, but not limited to, system operating limits, safety
and health
considerations, and information concerning applicable safety systems and
their functions.
C.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428 - the
2011
PHA
Revalidation was not complete and accurate in that the Process Safety
Information related to the
ventilation system design for the Main Plant Engine Room was only
available in the form of a
contractor's proposal dated July 26, 2005.

Issued

Aug 14, 2012

Abate by

Dec 31, 2012

General-duty citation text

29 CFR 1910.119(e)(7):  The employer did not retain process hazards
analyses, updates, or
revalidations for each covered process, as well as the documented
resolution of recommendations
described in 29 CFR 1910.119(e)(5) for the life of the process:
A.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428 - On or
about February
16, 2012, the documents and records retained from the 2002 PHA
revalidation for the Main
Plant Engine Room consisted of two sheets of paper containing hand written
notes.  No
additional documentation to indicate specific PHA procedural steps or
resolution of
recommendations was available.
B.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428 - On or
about
February
16, 2012, the documents and records retained from the 2011 PHA
revalidation for the Main
Plant Engine Room consisted of a six page typed summary of the PHA
revalidation process.
No additional documentation to indicate specific PHA procedural steps or
resolution of
recommendations was available.

Issued

Aug 14, 2012

Abate by

Dec 31, 2012

Penalty

Initial $4,250 · Current $2,760 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(B):  The employer's written operating procedures
covering the steps
for each operating phase did not address normal oil draining operations:
a.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428 - On or
about February
16, 2012, and at times prior thereto, site specific operating procedures
for oil draining
operations from each drain point in the ammonia refrigeration system in
the Main Plant Engine
Room had not been developed.  Employees utilized general procedures from
an International
Institute of Ammonia Refrigeration (IIAR) poster titled "IIAR Recommended
Oil Draining
Guidelines" to conduct oil draining operations.

Issued

Aug 14, 2012

Abate by

Dec 31, 2012

General-duty citation text

29 CFR 1910.119(f)(1)(i)(D):  The employer's written operating procedures
covering
the steps
for each operating phase did not address emergency shutdown, including the
conditions under
which emergency shutdown is required and the assignment of shutdown
responsibility to
qualified operators, to ensure that emergency shutdown is executed in a
safe and timely manner:
a.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428 - On or
about, February
16, 2012, and at times prior thereto, Emergency Shutdown procedures for
the Main Plant Engine
Room had not been developed.  General shutdown guidance was part of the
company's
Emergency Response Plan.

Issued

Aug 14, 2012

Abate by

Dec 31, 2012

General-duty citation text

29 CFR 1910.119(f)(1)(i)(F):  The employer's written operating procedures
covering the steps
for each operating phase did not address normal shutdown:
a.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428 - On or
about, February
16, 2012, and at times prior thereto, Normal Shutdown procedures for the
Main
Plant Engine
Room had not been developed.  The company utilized maintenance Lockout
Tagout procedures
and manufacturer's maintenance manuals to shutdown specific equipment.

Issued

Aug 14, 2012

Abate by

Dec 31, 2012

Penalty

Initial $4,250 · Current $2,765 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(ii):  The employer's written operating procedures
did not address the
requirements for the operating limits listed in 29 CFR
191.119(f)(1)(ii)(A) and (B):
A.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428 - On or
about February
16, 2012, and at times prior thereto, the standard operating procedures
developed for the Main
Plant Engine Room did not contain specific information related to the
Operating Limits relevant
to the equipment addressed in the procedures.  The company's procedures
stated to refer to
specific manufacturer's manuals for information about operating limits.
B.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428 - On or
about February
16, 2012, and at times prior thereto, Preventative Maintenance procedures
did
not identify the
operating limits related to the equipment being worked on / maintained.
The procedures
contained basic inspection steps and blank inspection forms to be
completed by the employee.
ABATEMENT NOTE:
1910.119(f)(1)(ii)(A): Consequences of deviation from the operating
limits; and
1910.119(f)(1)(ii)(B): Steps required to correct or avoid deviation.

Issued

Aug 14, 2012

Abate by

Dec 31, 2012

General-duty citation text

29 CFR 1910.119(f)(1)(iii):  The employer's written operating procedures
did not address the
requirements for the safety and health considerations listed in 29 CFR
1910.119(f)(1)(iii)(A)
through (f)(1)(iii)(E):
A.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428 - On or
about February
16, 2012, and at times prior thereto, the standard operating procedures
developed for the Main
Plant Engine Room did not contain specific information related to the
Safety and Health
Considerations relevant to the equipment and materials addressed in the
procedures.  The
company's procedures stated to wear safety glasses, have an ammonia mask
available, and refer
to the Process Hazard Analysis (PHA) for information concerning potential
scenarios that could
lead to a release.
B.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428 - On or
about February
16, 2012, and at times prior thereto, Preventative Maintenance procedures
did not contain
specific information related to the Safety and Health Considerations
related to the equipment
being worked on / maintained.  Printed work orders containing the
Preventative Maintenance
procedures only stated to ensure Lockout Tagout is followed when necessary.
ABATEMENT NOTE:
Safety and health considerations include the following:
1.) Properties of, and hazards presented by, the chemicals used in the
process;
2.) Precautions necessary to prevent exposure, including engineering
controls,
administrative controls, and personal protective equipment;
3.) Control measures to be taken if physical contact or airborne exposure
occurs;
4.) Quality control for raw materials and control of hazardous chemical
inventory levels;
and,
5.) Any special or unique hazards.

Issued

Aug 14, 2012

Abate by

Dec 31, 2012

General-duty citation text

29 CFR 1910.119(f)(1)(iv):  The employer's written operating procedures
did not address safety
systems and their functions:
A.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428 - On or
about February
16, 2012, and at times prior thereto, the standard operating procedures
developed for the Main
Plant Engine Room did not contain specific information related to the
Safety Systems and their
functions relevant to the equipment addressed in the procedures.  The
company's procedures
stated to refer to specific manufacturer's manuals for information about
system safeties and set-
points.
B.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428 - On or
about February
16, 2012, and at times prior thereto, Preventative Maintenance procedures
developed for the
Main Plant Engine Room did not contain any information related to the
Safety Systems and their
functions relevant to the equipment addressed in the procedures.

Issued

Aug 14, 2012

Abate by

Dec 31, 2012

Penalty

Initial $4,250 · Current $2,765 Reduced

General-duty citation text

29 CFR 1910.119(f)(3):  The emploer did not certify annually that the
operating
procedures are
current and accurate:
a.) Welch Foods, Inc., 139 South Lake Street, North East, PA 16428 - On or
about February
16, 2012, the Company had not certified that the written operating
procedures for the Main Plant
Engine room were reviewed on an annual basis to ensure they were current
and accurate.  The
most recent date documented on the operating procedures was October 2007.