OSHA Inspection: RANA MEAL SOLUTIONS, LLC.

Issued

Jan 18, 2013

Penalty

Initial $4,000 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.101(b):  Section 3.4.4, Compressed Gas Association Pamphlet P-1 (1965), as adopted by 29 CFR 1910.101(b):  Compressed gas cylinder(s) in use were not properly supported to prevent them from being knocked over:    a) Rana Meal Solutions LLC. - The employer did not ensure that approximately 32 compressed gas cylinder(s) in use, located in the production department next to the pasta packaging line, were supported to prevent them from being knocked over.

Issued

Jan 18, 2013

Abate by

Apr 19, 2013

Penalty

Initial $5,000 · Current $2,500 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(d)(3)(i)(G):  Process safety information pertaining to the equipment did not include the material and energy balances for processes built after May 26, 1992:    a) Rana Meal Solutions LLC. - The employer did not develop process safety information pertaining to the equipment which included the material and energy balances for the ammonia refrigeration system.

Issued

Jan 18, 2013

Abate by

Apr 19, 2013

Penalty

Initial $5,000 · Current $2,500 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(e)(3)(i):  The process hazard analysis did not address the hazards of the process:    a) Rana Meal Solutions, LLC. - The employer's process hazard analysis did not address hazards of its ammonia refrigeration processes that were not controlled as prescribed by the ANSI/ASHRAE (American Society of Heating, Refrigerating and Air Conditioning Engineers) Standard 15,  "Safety Standard for Refrigeration Systems" or an equivalent standard.      Such hazards included, but are not limited to:    In the refrigeration processes:    A) The absence of visible and audible ammonia alarms inside the engine rooms, and outside each entrance to the engine rooms, with manual resets located inside the engine rooms and with the meaning of each alarm clearly marked by signage near the annunciators.    B) The absence of legible permanent signs, securely attached and easily accessible, reading "Engine Room - Authorized Personnel Only" and further communicating that entry is forbidden except by those personnel trained in emergency procedures when the ammonia alarm has been activated.    C) Door(s) communicating with the engine rooms were not tight fitting, permitting passage of escaping ammonia to other work areas of the building.    D) Piping piercing the interior walls of the engine were not tightly sealed to the walls permitting passage of escaping ammonia to other work areas.    E) Emergency shutdown procedures including precautions to be observed in case of a breakdown or leak, were not posted outside each engine room, immediately adjacent to each door.    In addition,     F) Ammonia sensors, were mounted on high ceilings of the engine room, may not be able to detect releases of ammonia that form dense mixtures of ammonium hydroxide which tend to travel along the ground rather than rise rapidly.

Issued

Jan 18, 2013

Abate by

Apr 19, 2013

Penalty

Initial $5,000 · Current $2,500 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(f)(1):  The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities in each covered process consistent with the process safety information and which addressed the elements listed in 29 CFR 1910.119(f)(1)(i) through (f)(1)(iv):    a) Rana Meal Solutions LLC. - The employer failed to have implemented written operating procedures for each operating phase of the process. There were no written operating procedures for ammonia refrigeration equipment which included the evaporators, condensers, pressure vessels and associated pumps and oil pots that detailed the procedures for normal operations, normal shutdown, temporary operations; emergency operations, normal shutdown and safety and health considerations or for startup after a turnaround. Additionally, there were no written operating procedures for emptying the oil pot.

Issued

Jan 18, 2013

Abate by

Apr 19, 2013

Penalty

Initial $5,000 · Current $2,500 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(h)(2)(iii):  The employer did not explain to contract employers the applicable provisions of the emergency action plan required by 29 CFR 1910.119(n):    a) Rana Meal Solutions LLC. -The employer did not explain to contract employers from Kramer Mechanical LLC operating the ammonia refrigeration system, the applicable provisions of the emergency action plan.

Issued

Jan 18, 2013

Abate by

Apr 19, 2013

Penalty

Initial $5,000 · Current $2,500 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(i)(2)(iii): For new facilities, a process hazard analysis was not  performed and recommendations were not resolved or implemented before startup.    a) Rana Meal Solutions LLC  The employer did not ensure the process hazard analysis was performed for new facilities and recommendations were resolved or implemented prior to the introduction of over 10,000 pounds of anhydrous ammonia to the refrigeration system which occurred on August 18, 2012.    The following recommendations were not implemented prior to August 18, 2012    1) Rana should consider using the ammonia detectors in the plant to activate a cutoff of the ammonia liquid supply to that area.    2) Rana should ensure that a compliance Emergency Response Plan is in place prior to employees beginning work.    3) Rana should ensure that a compliant employee orientation plan is in place prior to employees beginning work.    4) Rana should ensure that the planned ammonia detectors are installed.    5) Rana should ensure that the planned eye wash and shower station are installed.    6) Rana should ensure that the designed ventilation system is installed as required.    7) Rana should ensure that the Contractor Qualification program is in place and that all contractors are qualified to work in the compressor room.    8) Rana should ensure that forklift and manlift operators are properly trained and qualified.    9) Rana should ensure that operator/mechanics who operate the ammonia system are properly trained and qualified, whether these are in-house operators or outside contractors.    10) Rana should ensure that a compliant Lockout/Tagout procedure is in place and used by both in house mechanics and outside contractors.    11) Rana should coordinate with the local Fire Department and the Local Emergency Planning Council (LEPC) for response to emergencies.    12) Rana should ensure that the Mechanical Integrity/Preventive Maintenance program is implemented and documented.    13) Rana should ensure that a compliant Hot Work Procedure is in place for both in-house mechanics and outside contractor mechanics.    14) Rana should ensure that compliant confined space entry program is in place and used by both in-house mechanics and outside contractors.    15) Rana should ensure that appropriate personal protective equipment (facemask, gloves, ets is provided for all mechanics and training has been provided in their use.    16) Rana should ensure that outside contractors are given orientation about the plant and procedure including roof egress points.    17) Rana should ensure that the operator/mechanics either in-house or outside contractors are trained in the standard operating procedures prior to operating equipment.    18) Rana should consider annual vibration testing for compressor to maintain their integrity over time.    19) Rana should consider having an ammonia detector in the RV piping header to alert personnel to leaking RV valves.     20) Rana should ensure that the coalescing filter is on regular manufacturer recommended PM (either in-house mechanics or an outside contractor.)    21) Rana should consider having periodic oil analysis to monitor compressor condition.    22) Rana should ensure that there is an annual PM on the high level cutouts on the recirculator.    24) Rana should consider having night time security include a walkthrough of the compressor room.    25) Rana should consider locking out and tagging the drain on the HPR.    26) Rana should consider locking out and tagging out the grain valve on the sight glass column.     27) Rana should ensure that low temp. piping is either rated for the temperatures used or stress tested and certified.     28) Rana should ensure that a check valve is installed and functional in the ammonia charging line.    29) Rana should ensure that a compliant SOP for ammonia charging is implemented and used.    30) Rana should ensure that the ammonia charging line on the HPR is properly guarding from traffic.

Issued

Jan 18, 2013

Abate by

Mar 29, 2013

Penalty

Initial $5,000 · Current $2,500 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(n): The employer did not establish and implement an emergency plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan shall include procedures for handling small releases.     a) Rana Meal Solutions LLC - The employer did not establish and implement an emergency plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan shall include procedures for handling small releases of ammonia.

Issued

Jan 18, 2013

Penalty

Initial $5,000 · Current $2,500 Reduced

Hazardous substances 017022602310

General-duty citation text

29 CFR 1910.151(c):  Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.    a. ) Rana Meal Solutions LLC, the engine room.  The employer did not ensure when employees were exposed to injurious corrosive material that suitable facilities for quick drenching or flushing of the eyes were not within the work area for immediate emergency use. The ammonia refrigeration engine room did not have a pedestal mounted eyewash and shower station installed. Employees that work in the ammonia refrigeration engine room were exposed to corrosive material which include anhydrous ammonia (pH 12) when conducting ammonia refrigeration maintenance operations.    b.) Rana Meal Solutions LLC, the wastewater treatment department.  The employer did not ensure when employees were exposed to injurious corrosive material that suitable facilities for quick drenching of flushing or the eyes were not within the work area for immediate emergency use. The wastewater treatment department did not have a pedestal mounted eyewash and shower station installed. Employees that work in the wastewater treatment department are exposed to corrosive material which include liquid caustic soda 50 % or sodium hydroxide (pH 14) and sulfuric acid 66 degrees (pH 1) when conducting equipment maintenance operations.

Issued

Jan 18, 2013

Abate by

Mar 8, 2013

Penalty

Initial $5,000 · Current $2,500 Reduced

Hazardous substances 017022602310

General-duty citation text

29 CFR 1910.1200(e):  The employer did not develop, implement, and/or maintain at the workplace a written hazard communication program which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met:    a) Rana Meal Solutions LLC. -  The employer did not implement at the workplace a written hazard communication program in accordance with 29 CFR 1910.1200 that describes at least the following:    1) Requirement for labeling of containers or hazardous chemicals:  2) Material safety data sheet(s) availability;  3) Training of employees;  4) A complete list of hazardous chemicals known to be in the workplace;  5) Methods to inform employees of the hazards of non-routine tasks; and,  6) Methods to inform other employer(s) of material safety data sheets availability; the labeling system and any precautionary measures to protect employees.    The employees conducting production, maintenance and repair operations were exposed to hazardous chemicals, including, but not limited to: Anhydrous Ammonia (severely corrosive to the respiratory system) (pH -12) Sulfuric Acid 66 Degree (highly corrosive and is destructive to all tissue contacted and is likely to cause severe burns) (pH-1) and Liquid caustic Soda 50% (Short term-irritation (possibly severe), burns; Long term-dermatitis)(pH-14).

Issued

Jan 18, 2013

Abate by

Mar 8, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 017022602310

General-duty citation text

29 CFR 1910.1200(e)(1)(i):  The written hazard communication program did not include a list of the hazardous chemicals known to be present using an identity that was referenced on the appropriate material safety data sheet.    a) Rana Meal Solutions LLC. - The employer did not include a list of the hazardous chemicals known to be present using an identity that was referenced on the appropriate material safety data sheet. The employees conducting production, maintenance and repair operations were exposed to hazardous chemicals, including, but not limited to: Anhydrous Ammonia (severely corrosive to the respiratory system) (pH -12) Sulfuric Acid 66 Degree (highly corrosive and is destructive to all tissue contacted and is likely to cause severe burns) (pH -1) and Liquid caustic Soda 50% (Short term-irritation (possibly severe), burns; Long term-dermatitis)( pH -14).

Issued

Jan 18, 2013

Abate by

Mar 8, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 017022602310

General-duty citation text

29 CFR 1910.1200(g)(1):  The employer did not have a material safety data sheet for each hazardous chemical which they used:    a) Rana Meal Solutions LLC. - The employer did not have a material safety data sheet for each hazardous chemical. Employees conducting production, maintenance and repair operations were exposed to hazardous chemicals, including, but not limited to: Anhydrous Ammonia (severely corrosive to the respiratory system) (pH -12), Sulfuric Acid 66 Degree (highly corrosive and is destructive to all tissue contacted and is likely to cause severe burns) (pH -1) and Liquid caustic Soda 50% (Short term-irritation (possibly severe), burns; Long term-dermatitis)( pH -14).

Issued

Jan 18, 2013

Abate by

Mar 8, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 017022602310

General-duty citation text

29 CFR 1910.1200(h)(1):  Employees were not provided information and training as specified in 29 CFR 1910.1200(h)(1) and (2) on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard was introduced into their work area:     a)Rana Meal Solutions, LLC - The employer did not ensure employees were provided with effective information and training on the hazardous chemicals in their work area at the time of their initial assignment and whenever a new physical health hazard the employee have not previously been trained about was  introduced into their work area.     Employees conducting production, maintenance and repair operations were not trained on the hazardous chemicals in their work area, including, but not limited to: Anhydrous Ammonia (severely corrosive to the respiratory system) Sulfuric Acid 66 Degree (highly corrosive and is destructive to all tissue contacted and is likely to cause severe burns) and Liquid caustic Soda 50% (Short term-irritation (possibly severe), burns; Long term-dermatitis).

Issued

Jan 18, 2013

Abate by

Mar 8, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.22(a)(2): The floor of every workroom shall be maintained in a clean and, so far as possible, a dry condition. Where wet processes are used, drainage shall be maintained, and false floors, platforms, mats, or other dry standing places should be provided where practicable.    a) Rana Meal Solution LLC. -  The employer did not maintain the floor in a clean and, so far as possible, a dry condition. Where wet processes were used, drainage was not provided. In the engine room, next to the eyewash station, across from compressor 110, a constant stream of water was allowed to flow, across the main aisleway, to the drain approximately two feet away.