OSHA Inspection: ROSINA FOOD PRODUCTS, INC.

Issued

Dec 28, 2012

Abate by

Feb 2, 2013

Penalty

Initial $7,000 · Current $0 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 09/19/12, in the Ammonia Engine Room, Employer did not document and did not comply with RAGAGEP such as, but not limited to: ANSI/IIAR 2- 2008, Section 13.2.3.1.2 that the Ammonia Detection System/Vapor Sensors shall not exceed 1,000 ppm to activate the Ventilation System. The Ammonia Detection Sensor #2 was set at 15,000 ppm to activate the Emergency Ventilation Fans/Secondary Exhaust (EF 3&5).        ABATEMENT DOCUMENTATION REQUIRED

Issued

Dec 28, 2012

Abate by

Oct 1, 2013

Penalty

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

General-duty citation text

29 CFR 1910.119(e)(5):     The employer did not establish a system to promptly address the teams findings and recommendations; did not assure that the recommendations were resolved in a timely manner and that the resolution was documented; did not document what actions were to be taken; did not complete actions as soon as possible; did not develop a written schedule of when these actions were to be completed; did not communicate the actions to operating, maintenance and other employees whose work assignments were in the process and who may have been affected by the recommendations or actions:    Recent examples of this occurred on 09/19/12 and prior, when:    a) Throughout the facility, Corrective Actions/Recommendations identified during the 2008 Process Hazard Analysis (PHA) did not have Actual Completion Date for Item 1.1. Screw Compressors #1-#5, Main System, Corrective Action 16b: "Find out when the need to change the oil is and establish a timeframe".     b) Throughout the facility, Corrective Actions/Recommendations identified during the 2008 PHA did not have Scheduled and Actual Completion Dates for Item 1.1. Screw Compressors #1-#5, Main System, Corrective Action 35c: "Annual inspection of safety cutouts".    c) Throughout the facility, Corrective Actions/Recommendations identified during the 2008 PHA did not have Scheduled and Actual Completion Dates for Item 3.1. High Pressure Receiver(HPR), Main System, Corrective Actions 1c, 6b, 16c: Write Standard Operating Procedure (SOP) for the proper isolation and pump out of HPR.    d) Throughout the facility, Corrective Actions/Recommendations identified during the 2008 PHA did not document Corrective Actions to be taken and did not have Scheduled and Actual Completion Dates for Item 4.1 Chillers with Oil Pots, 15c, 17b. In this Item, it was stated as a control to prevent damage to Chillers and an Ammonia release the use of existing written operating procedures(SOPs) for the proper isolation and pump out of Chillers. However, Employer did not develop and document these SOPs yet.    e) Throughout the facility, Corrective Actions/Recommendations identified during the 2008 PHA did not have Scheduled and Actual Completion Dates for Item 6.1. Ammonia Still, Main System, Corrective Actions 10b, 23d: Write Standard Operating Procedure (SOP) for the proper isolation of the Ammonia Still.     f) Throughout the facility, Corrective Actions/Recommendations identified during the 2008 PHA did not have a Scheduled and Actual Completion Dates for Item 9.1. Transfer System Vessel with Pump, Main System, Corrective Actions 3, 13d: Write Standard Operating Procedure (SOP) for Transfer System.    g) Throughout the facility, Corrective Actions/Recommendations identified during the 2008 PHA did not document Corrective Actions to be taken and did not have Scheduled and Actual Completion Dates for Item 10.1 Purger, Main System, 4e. In this Item, it was stated as a control to prevent an Ammonia release the use of an existing written operating procedure(SOP) for the proper isolation and pump out of Purger. However, Employer did not develop and document this SOP yet.    h) Throughout the facility, Corrective Actions/Recommendations identified during the 2008 PHA did not have Scheduled and Actual Completion Dates for Item 11.1. Ammonia Lines, Main System, Corrective Action 1b: Write Standard Operating Procedure (SOP) for the proper isolation of Ammonia Lines.    ABATEMENT DOCUMENTATION REQUIRED

Issued

Dec 28, 2012

Abate by

Oct 1, 2013

Penalty

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

General-duty citation text

29 CFR 1910.119(f)(1)(i):     The employer's written operating procedures covering the steps for each operating phase did not address initial startup, normal operations, temporary operations, 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, emergency operations, normal shutdown, and startup following a turnaround, or after an emergency shutdown:     Recent examples of this occurred on 09/19/12, when:    a) In the establishment, Standard Operating Procedure (SOP) for the Proper Isolation and Pump Out of High Pressure Receiver was not developed and documented.    b) In the establishment, Standard Operating Procedure (SOP) for the Proper Isolation and Pump Out of Chillers was not developed and documented.    c) In the establishment, Standard Operating Procedure (SOP) for the Proper Isolation of the Ammonia Still was not developed and documented.    d) In the establishment, Standard Operating Procedure (SOP) for Transfer System Vessel with pump was not developed and documented.    e) In the establishment, Standard Operating Procedure (SOP) for the Proper Isolation and Pump Out of Purger was not developed and documented.    f) In the establishment, Standard Operating Procedure (SOP) for the Proper Isolation of Ammonia Lines was not developed and documented.      ABATEMENT DOCUMENTATION REQUIRED

Issued

Dec 28, 2012

Abate by

Oct 1, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(1)(ii):     The employer's written operating procedures did not address operating limits, consequences of deviation and the steps required to correct or avoid deviation beyond such operating limits:    In the establishment, Employer's Ammonia Standard Operating Procedures (SOPs) did not provide clear instructions for safely conducting activities involved in operating the Ammonia Refrigeration System, as SOPs such as, but not limited to:    a) On or about 09/09/12, General Oil Draining Procedure # 96-010 did not address operating limits, consequences of deviation and the steps required to correct or avoid deviation for specific Oil Drain Points, such as, but not limited to: Oil Pot V-16-Chiller CH-1; Oil Pot V-20- Chiller CH-3; Oil Pot V-18-Chiller CH-2; Ammonia Still V-11; Oil Pot V-28 (V-13 LT Accumulator); Oil Pot V-27 (V-14 Intercooler).     b) On or about 09/09/12, Ammonia Draining Procedure # 96-013 did not address operating limits, consequences of deviation and the steps required to correct or avoid deviation for process equipment, such as, but not limited to: Intercooler, Accumulator, Northfield Spiral Freezer, Distribution Center Freezer, Receiver (V-12, Main) and V-8 Freezer.     c) On or about 09/09/12, General Compressor Pump-down and Isolation Procedure # 96-011 did not address operating limits, consequences of deviation and the steps required to correct or avoid deviation for Compressors C1, C2, C3, C4 and C5.    d) On or about 09/09/12, Float Maintenance Procedure# 96-008 did not address operating limits, consequences of deviation and the steps required to correct or avoid deviation.      ABATEMENT DOCUMENTATION REQUIRED

Issued

Dec 28, 2012

Abate by

Oct 1, 2013

Penalty

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

General-duty citation text

29 CFR 1910.119(j)(2):     The employer did not establish written procedures to maintain the on-going mechanical integrity of process equipment:    Recent examples occurred on 09/19/12, when:    a) Throughout the Ammonia Refrigeration Facility, Employer did not establish written procedures for the testing of safety cutouts such as, but not limited to: High pressure cutouts, low pressure cutouts, oil pressure cutouts, high discharge temperature cutouts and high oil temperature cutouts on Compressors C1, C2, C3, C4, and C5.    b) Throughout the Ammonia Refrigeration Facility, Employer did not establish written procedures for oil analysis and oil changing on Compressors C1, C2, C3, C4, and C5.    c) Throughout the Ammonia Refrigeration Facility, Employer did not establish a written procedure for vibration analysis on Compressors C1, C2, C3, C4, and C5.    d) Throughout the Ammonia Refrigeration Facility, Employer did not establish written procedures for periodic inspections and testing of Ammonia detection/alarm system, high level alarms/high level emergency shutdown systems on process equipment such as, but not limited to: Accumulator and Intercooler.     e) Throughout the Ammonia Refrigeration Facility, Employer did not establish a written procedure for periodic inspections and preventive maintenance of Ammonia pumps such as: Viking Ammonia Still Pump, RP-3, Model: HL41950, Serial no: 10652637.    ABATEMENT DOCUMENTATION REQUIRED

Issued

Dec 28, 2012

Abate by

Apr 1, 2013

Penalty

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

General-duty citation text

29 CFR 1910.119(j)(4)(i):     The employer did not perform inspection and tests on process equipment to maintain its mechanical integrity:    A recent example of this occurred on 09/19/12, when:    a) Throughout the Ammonia Refrigeration Facility, Employer did not perform testing of safety cutouts such as, but not limited to: High pressure cutouts, low pressure cutouts, oil pressure cutouts, high discharge temperature cutouts and high oil temperature cutouts on Compressors C1, C2, C3, C4, and C5 at least annually.    b) Throughout the Ammonia Refrigeration Facility, Employer did not perform testing of Ammonia detection/alarm system, high level alarms/high level emergency shutdown systems on process equipment such as, but not limited to: Accumulator and Intercooler.       ABATEMENT DOCUMENTATION REQUIRED

Issued

Dec 28, 2012

Abate by

Apr 1, 2013

Penalty

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

General-duty citation text

29 CFR 1910.119(n):     Emergency planning and response. The employer shall establish and implement an emergency action 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. Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120 (a), (p) and (q).    a) On or about 09/19/12, in the establishment, Employer's Emergency Action Plan did not include procedures for handling small releases of Anhydrous Ammonia from process equipment such as, but not limited to, the Ammonia release incident from a transfer pump occurred on 09/09/09.      ABATEMENT DOCUMENTATION REQUIRED

Issued

Dec 28, 2012

Abate by

Apr 1, 2013

Penalty

Initial $4,250 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.147(c)(4)(i):     Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:    a) On or about 09/19/12, in the establishment, Employer did not develop and document machine-specific Lockout/Tagout (LOTO) procedures for machines such as, but not limited to: BOC/Nitrogen Tunnel and San Rallo Nitrogen Tunnel.    ABATEMENT CERTIFICATION REQUIRED

Issued

Dec 28, 2012

Abate by

Apr 1, 2013

Penalty

Initial $4,250 · Current $0 Reduced

General-duty citation text

29 CFR 1910.147(c)(6)(i):     The employer did not conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirement of this standard were being followed:    a) On or about 09/19/12, in the establishment, Employer did not perform periodic inspections of their machine-specific Lockout/Tagout (LOTO) procedures for machines such as, but not limited to: air compressor, steam boiler (clayton 1 and 2), condensor water supplies, pump 2 and 3, evaporator fan units, hydraulic compactor, compressors, ishida scale, ilapack #1, pasta machines (techno-design), lyco blancher, weiler meat grinder, breader pumps, fast back conveyor, metal detector of FEMC line and Nitrogen Tunnels.       ABATEMENT CERTIFICATION REQUIRED

Issued

Dec 28, 2012

Abate by

Apr 1, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(c)(6)(ii):     The employer did not certify that periodic inspections of the energy control procedures had been performed:    a) On or about 09/19/12, in the establishment, Employer did not have certifications showing that lockout/tagout procedures had been inspected by authorized employees at least annually for machines such as, but not limited to: air compressor, steam boiler (clayton 1 and 2), condensor water supplies, pump 2 and 3, evaporator fan units, hydraulic compactor, compressors, ishida scale, ilapack #1, pasta machines (techno-design), lyco blancher, weiler meat grinder, breader pumps, fast back conveyor, metal detector of FEMC line and Nitrogen Tunnels.     ABATEMENT CERTIFICATION REQUIRED

Issued

Dec 28, 2012

Abate by

Apr 1, 2013

Penalty

Initial $4,250 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.147(f)(3)(i):     A procedure was not utilized to afford the employees a level of protection equivalent to that provided by the implementation of a personal lockout or tagout device when servicing and/or maintenance was performed by a crew, craft,    a) On or about 09/19/12, in the production areas, a group lockout/tagout procedure was not utilized when two employees were fixing a hydraulic problem/safety switch on a BOC/Nitrogen Tunnel.     b) On or about 09/19/12, in the production areas, a group lockout/tagout procedure was not utilized when two employees were repairing bad bearings on a Fast Back Conveyor.     c) On or about 09/19/12, in the production areas, a group lockout/tagout procedure was not utilized when two employees were changing a motor on a Metal Detector of the FEMC line.      ABATEMENT CERTIFICATION REQUIRED

Issued

Dec 28, 2012

Abate by

Apr 1, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(c)(4)(ii)(C):     The energy control procedure did not clearly and specifically outline the steps for placement, removal and transfer of lockout devices or tagout devices and the responsibility for them:    a) On or about 09/19/12, in the establishment, Employer's Energy Control Program(Lockout/Tagout Program) did not specify and document procedures for removal and notification of lockout/tagout (LOTO) devices by other than the authorized employees who applied them. Employer's LOTO program did not have procedures for: a) Verification by the Employer that authorized employees who applied LOTO devices were not at the facility, b) Notification by the Employer informing authorized employees that their LOTO devices had been removed and c) Procedures to ensure that these authorized employees had this knowledge before they resume work at the facility.       ABATEMENT CERTIFICATION REQUIRED