OSHA Inspection: RITE STUFF FOODS, INC

Issued

Aug 29, 2011

Abate by

Mar 20, 2012

Penalty

Initial $3,825 · Current $2,295 Reduced

General-duty citation text

29 CFR 1910.38(f)(2):  An employer did not review the emergency action plan with each employee covered by the plan;   (1) When the plan is developed or the employee is assigned initially to a job; (2) When the employee\'s responsibilities under the plan change; and (3) When the plan is changed.    (a)  On or about April 18, 2011, and at times prior thereto, employees and management did not have a common emergency response procedure for refrigeration technicians.  One procedure involved plant evacuation and the other involved technicians going back in to shut down equipment using a self-contained breathing apparatus.    Note:  Abatement certification and documentation ARE required for this item.

Issued

Aug 29, 2011

Abate by

Mar 20, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(g)(3):  The employer did not ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The employer did not prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.        (a)  On or about April 18, 2011, and at times prior thereto, employees did not have adequate knowledge of the companys written emergency action plan and of routine responses to ammonia refrigeration system leaks and releases.      Note:  Abatement certification and documentation ARE required for this item.

Issued

Aug 29, 2011

Abate by

Mar 20, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(n):  The employer did not establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38, and the employer's emergency action plan did not include procedures for handling small releases.                                                                                                                            (a)  On or about April 18, 2011, and at times prior thereto, the employer did not provide consistent procedures, in the emergency action plan, for handling responses to ammonia refrigeration system leaks and releases.      Note:  Abatement certification and documentation ARE required for this item

Issued

Aug 29, 2011

Abate by

Dec 20, 2011

Penalty

Initial $6,300 · Current $3,780 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B):  The process safety information did not include information pertaining to the equipment in the process:  \r\n\r\n(a)   On or about April 18, 2011, and at times prior thereto, Ammonia Refrigeration System, the P&ID drawings did not match the actual valve numbers, sequence of valves; and extra components.  Equipment P&IDs include, but are not limited to Compressor B and Compressor E. \r\n\r\n(b)   On or about April 18, 2011, and at times prior thereto, RREC-1, Cold Storage Recirculator, the P&ID drawings did not show the direction of flow in and out of the oil pot.\r\n\r\n(c)   On or about April 18, 2011, and at times prior thereto, Ammonia Refrigeration System, the P&ID drawings were not updated with existing valve/component numbers for equipment including, but not limited to the RREC-1 Cold Storage Recirculator; SC-1 Subcooler; REC-1 Freezer Recirculator; HPR1-1 High Pressure Receiver; EC1-1 Evaporative Condenser and EC1 Evaporative Condenser.\r\n\r\n(d)   Machinery Room; On or about April 18, 2011, and at times prior thereto, a new Compressor A (GEA FES, Inc - 2010) was not identified on the P&ID drawings as a replacement for the older Vilter compressor.\r\n\r\n(e)   Machinery Room; On or about April 18, 2011, and at times prior thereto, AP-1; Auto Purger, Purge Valve Assembly was not identified on the P&ID drawings.\r\n\r\n(f)   Machinery Room; On or about April 18, 2011, and at times prior thereto, Pressure Relief Valves for REC-1; Freezer Recirculator and the adjoining REC-1 Oil Pot were not identified on the P&ID drawings.\r\n\r\n(g)   Machinery Room; On or about April 18, 2011, and at times prior thereto, the valve going to AP-1 Auto Purgers from the 2 inch, High Pressure Liquid (HPL) line to Cooler Room 1 was not identified on the P&ID drawings.\r\n\r\n(h)   Outside Evapco Evaporative Condensers, on or about April 18, 2011, and at times prior thereto, the valves to and from EC1 and EC1-1 evaporative condensers were not adequately tagged to match the P&ID drawings.\r\n\r\nNote: Abatement certification and documentation ARE required for this item.  \r\n

Issued

Aug 29, 2011

Abate by

Apr 1, 2013

Penalty

Initial $6,300 · Current $3,780 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii):  The employer did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP).         (a)   On or about April 18, 2011, and at times prior thereto, the employer did not document that relief venting for Machinery Room equipment complied with RAGAGEP in that, the relief vents were at approximately 8-9 feet above the work surface, which is less than the required 15 feet above the adjacent grade or roof level.  Machinery Room equipment includes, but is not limited to SC-1 Subcooler; REC-1 Freezer Recirculator; and Compressors A, B, D & E.       (b)   On or about April 18, 2011, and at times prior thereto, the employer did not document that ammonia refrigeration system piping and components were properly identified.  Examples include, but are not limited to, the High Pressure Receiver (HPR1-1) and Evaporative Condensers (EC1 and EC1-1).       (c)   On or about April 18, 2011, and at times prior thereto, the employer did not document that the Machinery Room contained an ammonia detector, located in an area where refrigerant would concentrate, that actuates an alarm and mechanical ventilation both automatically and manually.     (d)   On or about April 18, 2011, and at times prior thereto, the employer did not document that Machinery Room ventilation discharge of air was safe and not able to cause a nuisance or danger to employees conducting routine maintenance tasks on the High Pressure Receiver or Evaporative Condensers or Propane fueling or to employees who may be evacuating from the North side of the Machinery Room.      (e)   On or about April 18, 2011, and at times prior thereto, the employer did not document that the area around the RREC-1 Cold Storage Recirculator, met the design requirements of a machinery room.      (f)   On or about April 18, 2011, and at times prior thereto, the employer did not document that the ceiling openings for the machinery room, compressor D, were tight fitting.  The ceiling openings were visible and leaking rain at the time of the inspection.

Issued

Aug 29, 2011

Abate by

Apr 1, 2013

Penalty

Initial $6,300 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(o)(4):  The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.                               (a)   On or about April 18, 2011, and at times prior thereto, the employer did not adequately document deficiencies of the Process Safety Management program during the PSM Internal Compliance Audit, December 18, 2009.  Process Safety Information [1910.119(d)(3)(i)], deficiencies discovered during this inspection, include, but are not limited to, the Machine Room, Electrical Classification, Ventilation System Design, and Safety Systems (ammonia detection and alarm).    (b)  On or about April 18, 2011, and at times prior thereto, the employer did not adequately document deficiencies of the Process Safety Management program during the PSM Internal Compliance Audit, December 18, 2009.  Process Safety Information [1910.119(d)(3)(ii)], deficiencies discovered during this inspection, include, but are not limited to the Machine Room, relief vents not being over 15 feet above the adjacent grade; for piping and components not properly identified; for no ammonia detector, alarm for ammonia; for ventilation discharge hazards; for not having tight fitting ceiling penetrations; and the Cold Storage Recirculator not being in a machine room.    (c)  On or about April 18, 2011, and at times prior thereto, the employer did not adequately document deficiencies of the Process Safety Management program during the PSM Internal Compliance Audit, December 18, 2009.  Operating Procedures [1910.119(f)], deficiencies discovered during this inspection include, but are not limited to operating procedures dealing with ammonia detection system, emergency sensing/alarm and emergency ventilation; removal of ice from cold storage piping; testing of safety cut-outs; and oil pot drainage referring to P&IDs containing unidentified valves.    (d)  On or about April 18, 2011, and at times prior thereto, the employer did not adequately document deficiencies of the Process Safety Management program during the PSM Internal Compliance Audit, December 18, 2009.  Management of Change [1910.119(j)(2))], deficiencies discovered during this inspection include, but are not limited to mechanical integrity procedures needed to assure pipe rust; equipment identification tags; flange torqueing; and ice build-up on pipes are identified and corrected.    (e)  On or about April 18, 2011, and at times prior thereto, the employer did not adequately document deficiencies of the Process Safety Management program during the PSM Internal Compliance Audit, December 18, 2009.  Management of Change [1910.119(l)] deficiencies discovered during this inspection include,  but are not limited to procedures to assure that the technical basis; the safety and health; the procedures; the time period; and authorization of proposed changes are taken into consideration.    Note:  Abatement certification and documentation ARE required for this item.

Issued

Aug 29, 2011

Abate by

Dec 20, 2011

Penalty

Initial $6,300 · Current $6,300

General-duty citation text

29 CFR 1910.119(e)(5):  The employer did not establish a system (for Process Hazard Analysis) to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner; and that the resolution is documented.      (a)   On or about April 18, 2011, and at times prior thereto, the employer did not adequately document deficiencies of the Process Safety Management program during the Process Hazard Analysis, July 11, 2006.  PHA Items 16.03; 16.27; 16.29; and 16.30 identified deficiencies, in the Machine Room, having to do with ventilation and detection methodologies to provide early warning of releases (e.g.; ammonia detectors and alarms tied to ventilation system).   These items were to be completed when budget allows.    (b)  On or about April 18, 2011, and at times prior thereto, the employer did not adequately document deficiencies of the Process Safety Management program during the Process Hazard Analysis, July 11, 2006.  PHA Item 16.02 identified deficiencies, in the Machine Room, having to do with the lack of emergency shutdown points outside of the machinery room per ANSI/IIAR2-1999, but no owner, due date, or action was documented.    (c)  On or about April 18, 2011, and at times prior thereto, the employer did not adequately document deficiencies of the Process Safety Management program during the Process Hazard Analysis, July 11, 2006.  PHA Item 8.11 identified deficiencies, in the identification of discharge relief valves. NO owner, due date, or action was documented.    (d)  On or about April 18, 2011, and at times prior thereto, the employer did not adequately document deficiencies of the Process Safety Management program during the Process Hazard Analysis, July 11, 2006.  PHA Item 15.55 identified deficiencies, in the Lock-out; Tag-out program, but no owner, due date, or action was documented.      Note:  Abatement certification and documentation ARE required for this item.

Issued

Aug 29, 2011

Abate by

Mar 20, 2012

Penalty

Initial $6,300 · Current $3,780 Reduced

General-duty citation text

29 CFR 1910.119(f)(1):  The employer did not develop and implement written operating procedures that provide clear instructions for safety conducting activities involved in each covered process consistent with the process safety information.     (a)   On or about April 18, 2011, and at times prior thereto, employees were not provided with up to date written operating procedures for all phases of the operation, specifically for an ammonia detection system, emergency sensing/alarm; and emergency ventilation.                                      (b)  Instance deleted in informal settlement.                                  (c)  On or about April 18, 2011, and at times prior thereto, employees were not provided with up to date written operating procedures for all phases of the operation, specifically for the testing of safety cut-outs for compressor temperature and pressure.                                     (d)  Instance deleted in informal settlement.        Note:  Abatement certification and documentation ARE required for this item.

Issued

Aug 29, 2011

Abate by

Mar 20, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(3):  The operating procedures were not reviewed as often as necessary to assure that they reflect current operating practice and the employer did not certify annually that these operating procedures are current and accurate.         (a)   On or about April 18, 2011, and at times prior thereto, the employer did not provide up-to-date and annually certified written operating procedures for all phases of the operation.  The last review dates for procedures were in September-October 2009.                                                           Note:  Abatement certification and documentation ARE required for this item.

Issued

Aug 29, 2011

Abate by

Mar 20, 2012

Penalty

Initial $6,300 · Current $3,780 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 integrity of process equipment.                                    (a)  On or about April 18, 2011, and at times prior thereto, written mechanical integrity procedures and documentation were not in place for repair of piping and valves showing signs of degradation and rust, for the High Pressure Receiver and related unprotected piping.                            (b)  On or about April 18, 2011, and at times prior thereto, written mechanical integrity procedures were not in place for missing identification tags on evaporative condensers EC-1 and EC1-1.                       (c)  On or about April 18, 2011, and at times prior thereto, written mechanical integrity procedures were not in place for torqueing of flange bolts on ammonia refrigeration system equipment.            (d)  Cold Storage; on or about April 18, 2011, and at times prior thereto, written mechanical integrity procedures were not documented to control ice build-up.       Note:  Abatement certification and documentation ARE required for this item.\r\n

Issued

Aug 29, 2011

Abate by

Mar 20, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5):  The employer did not correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation.    (a)  High Pressure Receiver and related unprotected piping, on or about April 18, 2011, and at times prior thereto, where pressure vessels, piping and valves showed signs of degradation and rust.    (b) Cold Storage; on or about April 18, 2011, and at times prior thereto, where ice build-up, that could endanger the ammonia refrigeration system piping, was not adequately controlled through chipping of accumulations.        Note: Abatement certification and documentation ARE required for this item.

Issued

Aug 29, 2011

Abate by

Sep 20, 2011

Penalty

Initial $6,300 · Current $3,780 Reduced

General-duty citation text

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 is fit tested or required to use the respirator in the workplace.                                 (a)  On or about April 18, 2011, and at times prior thereto, the employer did not provide medical evaluations for all boiler/refrigeration technicians and other employees, who are required to wear full-face cartridge respirators and/or self-contained breathing apparatus to operate and/or maintain refrigeration equipment and/or to respond to releases of ammonia.    Note: Abatement certification and documentation ARE required for this item.

Issued

Aug 29, 2011

Abate by

Sep 19, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(f)(2):  The employer did not ensure that an employee using a tight-fitting face piece respirator is fit tested prior to initial use of the respirator, whenever a different respirator face piece (size, style, model or make) is used, and at least annually thereafter.               (a)  On or about April 18, 2011, and at times prior thereto, the employer did not provide annual fit testing for all boiler/refrigeration technicians and other employees who are required to wear full-face cartridge respirators and/or self-contained breathing apparatus to operate and/or maintain refrigeration equipment and/or to respond to releases of ammonia.  The most recent documentation of fit tests were from April 2007.    Note: Abatement certification and documentation ARE required for this item.

Issued

Aug 29, 2011

Abate by

Sep 19, 2011

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.134(g)(1)(i)(A): The employer permitted respirators with tight-fitting face pieces to be worn by employees who have facial hair that comes between the sealing surface of the face piece and the face.          (a)  On or about April 18, 2011, and at times prior thereto, the employer did not require all boiler/refrigeration technicians and other employees who are required to wear full-face cartridge respirators and/or self-contained breathing apparatus to operate and/or maintain refrigeration equipment and/or to respond to releases of ammonia, to be clean shaven and not have excessive facial hair.    Note: Abatement certification and documentation ARE required for this item.

Issued

Aug 29, 2011

Abate by

Sep 19, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(l)(1): The employer did not conduct evaluations of the workplace as necessary to ensure that the provisions of the current written program are being effectively implemented and that it continues to be effective.     (a)  On or about April 18, 2011, and at times prior thereto, the employer did not provide evaluations demonstrating an effectively implemented respirator program.    Note: Abatement certification and documentation ARE required for this item.