OSHA Inspection: NEW ENGLAND CONFECTIONERY COMPANY, INC.

Issued

Apr 2, 2013

Abate by

May 17, 2013

Penalty

Initial $7,000 · Current $4,000 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B):   The employer's piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process.    (a) Location - Facility:  On or about 10/5/12, the supporting valves and piping for a pump out compressor added in 2007 were not represented in the employer's piping and instrument diagrams.  The valves and piping were added to equipment including but not limited to the high pressure receiver, the heat exchangers and compressors.

Issued

Apr 2, 2013

Abate by

May 17, 2013

Penalty

Initial $7,000 · Current $4,000 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): Information pertaining to the equipment in the process did not include a relief system design and design basis.    (a) Location - Facility:  On or about 10/5/12, the information pertaining to the equipment in the process did not include an adequate relief system design and design basis.

Issued

Apr 2, 2013

Abate by

May 17, 2013

Penalty

Initial $7,000 · Current $4,000 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(d)(3)(i)(E): Information pertaining to the equipment in the process did not include a ventilation system design.    (a) Location - Ammonia Room:  On or about 10/5/12, the information pertaining to the equipment in the process did not include an adequate ventilation system design.

Issued

Apr 2, 2013

Abate by

May 17, 2013

Penalty

Initial $7,000 · Current $3,000 Reduced

Hazardous substances 0170

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.    (a) Location - Facility:  The process hazard analysis did not identify a situation where the ammonia coils in the concentrator corroded at a rapid rate and had to be replaced prematurely.

Issued

Apr 2, 2013

Abate by

Jul 15, 2013

Penalty

Initial $7,000 · Current $4,000 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(f)(1)(i):     The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information that addressed steps for each operating phase.    (a) Location - Facility:  On or about 10/5/12, the employer did not develop and implement written operating procedures that provided clear instructions addressing normal operations for equipment including but not limited to compressors.    (b) Location - Facility:  On or about 10/5/12, the employer did not develop and implement written operating procedures that provided clear instructions addressing temporary operations for equipment including but not limited to pumps, compressors, condensers, air handling units, and heat exchangers.    (c) Location - Facility:  On or about 10/5/12, the employer did not develop and implement written operating procedures that provided clear instructions addressing the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner for equipment including but not limited to pumps, compressors, condensers, air handling units, and heat exchangers.    (d) Location - Facility:  On or about 10/5/12, the employer did not develop and implement written operating procedures that provided clear instructions addressing normal shutdown for equipment including but not limited to heat exchangers.    (e) Location - Facility:  On or about 10/5/12, the employer did not develop and implement written operating procedures that provided clear instructions addressing startup following a turnaround, or after an emergency shutdown for equipment including but not limited to pumps, compressors, condensers, air handling units, and heat exchangers.

Issued

Apr 2, 2013

Abate by

Jul 15, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(f)(1)(i)(E):  The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information that addressed emergency operations.    (a) Location - Facility:  On or about 10/5/12, the employer did not develop written operating procedures that provided clear instructions for safely conducting emergency operations with the ammonia coils in the concentrator.

Issued

Apr 2, 2013

Abate by

Jul 15, 2013

Penalty

Initial $7,000 · Current $3,000 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(f)(1)(ii):   The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information that addressed operating limits.    (a) Location - Facility:  On or about 10/5/12, the employer did not develop and implement written operating procedures that provided clear instructions addressing operating limits for equipment including but not limited to all pumps and compressors.

Issued

Apr 2, 2013

Abate by

Jul 15, 2013

Penalty

Initial $7,000 · Current $3,000 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(B):     The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information which addressed precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment.    (a) Location - Facility:  The employer did not develop and implement written operating procedures that provided clear instructions addressing precautions necessary to prevent exposure to employees operating equipment including but not limited to pumps and compressors.

Issued

Apr 2, 2013

Abate by

Jul 15, 2013

Penalty

Initial $7,000 · Current $3,000 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(f)(1)(iv): The employer failed to ensure that the Process Safety Management Standard Operating Procedures included safety systems and their functions.    (a) Location - Facility:  On or about 10/5/12, the employer did not develop and implement written operating procedures that provided clear instructions addressing safety systems and their functions for equipment such as alarms, detection systems, and visual indicators.

Issued

Apr 2, 2013

Abate by

Jul 15, 2013

Penalty

Initial $7,000 · Current $3,000 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(f)(3): Operating procedures were not reviewed as often as necessary to assure that they reflected current operating practices, and the employer did not certify annually that the operating procedures were current and accurate.    (a) Location - Facility:  On or about 10/5/12, the employer did not review and annually certify that written operating procedures were current and accurate for equipment including but not limited to pumps, compressors, condensers, air handling units, and heat exchangers.

Issued

Apr 2, 2013

Abate by

Sep 1, 2013

Penalty

Initial $7,000 · Current $3,000 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment.    (a) Location - Facility:  On or about 10/5/12, the employer did not establish written procedures detailing how to maintain the on-going integrity of process equipment for equipment including but not limited to pumps and compressors.    An example of a recognized and generally acceptable good engineering practice (RAGAGEP) for inspection, testing and preventative maintenance (ITPM) procedures for pumps and compressors would be IIAR Bulletin #110-1993, Guidelines for Start-up, Inspection and Maintenance of Ammonia Mechanical Refrigeration Systems (6.3 forcompressors  and 6.5 for pumps).

Issued

Apr 2, 2013

Abate by

Sep 1, 2013

Penalty

Initial $7,000 · Current $3,000 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment was not consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.    (a) Location - Facility:  On or about 10/5/12, the frequency of inspections and tests had not been established for the ammonia coils in the concentrator.

Issued

Apr 2, 2013

Abate by

May 17, 2013

Penalty

Initial $7,000 · Current $3,000 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(l)(1): The employer did not implement procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process.    (a) Location - Concentrator:  The employer did not implement management of change procedures when the ammonia coils in the concentrator were replaced by coils constructed of a different material (stainless steel).    (b) Location - Facility:  The employer did not implement procedures to manage changes in organizational structure.

Issued

Apr 2, 2013

Abate by

May 17, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(l)(3):     Employees involved in operating a process and maintenance and contract employees whose job tasks would be affected by a change in the process were not informed of and trained in the change prior to start-up of the process or affected part of the process.    (a) Location - Facility:  The employer did not inform of and/or train employees in changes to the organizational structure when it affected the safe operation and emergency response duties of the ammonia refrigeration system.

Issued

Apr 2, 2013

Abate by

Aug 1, 2013

Penalty

Initial $7,000 · Current $4,000 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(l)(2)(ii):   The management of change procedures did not assure that the impact of changes on safety and health were addressed prior to any change.    (a) Location - Facility:  The written operating procedures for management of change that were used by the company did not assure that thefor the impact of the changes on safety and health were addressed.