OSHA Inspection: ECHO LAKE FOODS, INC.

Issued

Jul 23, 2013

Abate by

Jun 2, 2014

Penalty

Initial $5,000 · Current $4,875 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): The employer did not include, in the process safety information compilation, the relief system design and the design basis.    (a) North Ammonia System: Process Safety Information (PSI) for the Relief System Design and Design Basis was not compiled to outline the relief capacity of the system. Additionally, expansion of the ammonia refrigeration system in 2010, 2011 and 2012 did not include relief system design and design basis.    (b) South Ammonia System: Process Safety Information (PSI) for the relief system design and design basis was not compiled to outline the relief capacity of the system.

Issued

Jul 23, 2013

Abate by

Jun 2, 2014

Penalty

Initial $5,000 · 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.    (a) South Ammonia Machine Room: Emergency mechanical ventilation ducted outside of the machine room was not designed according to recognized and generally accepted good engineering practices (RAGAGEP). Emergency ventilation discharge was directed downward and into the pathway of egress from the machine room instead of being discharged upwards.

Issued

Jul 23, 2013

Abate by

Jun 2, 2014

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.119(e)(1): The employer did not perform an initial process hazard analysis (hazard evaluation) on processes covered by 29 CFR 1910.119    (a) North Ammonia System: An inital process hazard analysis was not completed for the north ammonia system.

Issued

Jul 23, 2013

Abate by

Jun 2, 2014

Penalty

Initial $7,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(3)(iii): The process hazard analysis did not address engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases.    (a) South Ammonia System: The PHA does not address the engineering and/or administrative controls used to assure that the volume/level in specific equipment does not exceed limits. The engineering and administrative controls section generically referred to early detection methodologies as system safeties. The actual safety controls applied to the equipment or process were not specified, such as the type of level control used to warn of a high level of liquid.

Issued

Jul 23, 2013

Abate by

Jun 2, 2014

Penalty

Initial $0 · Current $3,000

General-duty citation text

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting.    (a) South Ammonia System: Facility siting was identified as item 16 within the June 2012 process hazard analysis (PHA). All questions identified within the facility siting evaluation were not completed to assess hazards with respect to positioning of employees and potential areas of ammonia releases. Examples are, but are not limited to: (1) access and egress from facilities for maintenance and emergencies, (2) housekeeping operations, (3) safety systems such as discharge of emergency ventilation exhaust, opening of pressure relief valves, safety shower and gas detector location, and (4) Are ammonia release points located away from public access roads and vehicular traffic within the plant.

Issued

Jul 23, 2013

Abate by

Jun 2, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(vi): The process hazard analysis did not address human factors.    (a) South Ammonia System: Human factors was identifed as item 17 within the June 2012 process hazard analysis (PHA). Questions were not developed to evaluate and consider the human factors impact on the operation of the covered process.

Issued

Jul 23, 2013

Abate by

Jun 2, 2014

Penalty

Initial $5,000 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not document what actions were to be taken to resolve PHA recommendations.    (a) Process Hazard Analysis (PHA) recommendations for the south ammonia refrigeration system were not addressed and resolved for all recommendations identified within the 2012 PHA. The following recommendations were not addressed and resolved:    - Item 1.7 Compressors  - Item 4.12 Pressure Vessels  - Item 15.10 and 15.11 Human Factors and Operator Process Interface

Issued

Jul 23, 2013

Abate by

Jul 7, 2014

Penalty

Initial $5,000 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(i)(B): The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and did not address normal operations.    A specific procedure for each oil drain point on the ammonia refrigeration system was not developed to detail the draining operation. The lack of detailed procedures for oil draining operations, as referenced in the instances below, potentially exposed workers to injury from contact with anhydrous ammonia which could be released from the system during oil draining operations.    (a) North Ammonia System: An oil draining procedure was not developed for draining oil from oil pot V-2A.    (b) North Ammonia System: An oil draining procedure was not developed for draining oil from oil pot V-3A.    (c) North Ammonia System: An oil draining procedure was not developed for draining oil from oil pot V-4A.    (d) South Ammonia System: An oil draining procedure was not developed for draining oil from oil pot V-203A.    (e) South Ammonia System: An oil draining procedure was not developed for draining oil from oil pot V-204A.    (f) South Ammonia System: An oil draining procedure was not developed for draining oil from oil pot V-205A.

Issued

Jul 23, 2013

Abate by

Jul 7, 2014

Penalty

Initial $5,000 · Current $1,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(ii): 29 CFR 1910.119(f)(1)(ii):  The employers written operating procedures did not address the requirements for the operating limits listed in 29 CFR 1910.119(f)(1)(ii)(A) and (B):     (a) North Ammonia System:  Evaporator Cooling Unit EV-1 safety systems as outlined in procedure YOR-OP-026 did not list High suction pressure alarm set point.    (b) North Ammonia System: Evaporating Cooling Unit EV-2 safety systems as outlined in procedure YOR-OP-027 did not list high suction pressure alarm set point.    (c) North Ammonia System:  Evaporator Cooling Unit EV-3 safety systems as outlined in procedure YOR-OP-028 did not list High suction pressure alarm set point.    (d) North Ammonia System:  Evaporator Cooling Unit EV-4 safety systems as outlined in procedure YOR-OP-029 did not list High suction pressure alarm set point.    (e) North Ammonia System:  Evaporator Cooling Unit EV-5 safety systems as outlined in procedure YOR-OP-030 did not list High suction pressure alarm set point.    (f) North Ammonia System:  Evaporator Cooling Unit EV-6 safety systems as outlined in procedure YOR-OP-031 did not list High suction pressure alarm set point.    (g) North Ammonia System:  Evaporator Cooling Unit EV-7 safety systems as outlined in procedure YOR-OP-032 did not list High suction pressure alarm set point.    (h) North Ammonia System:  Evaporator Cooling Unit EV-8 safety systems as outlined in procedure YOR-OP-033 did not list High suction pressure alarm set point.    (i) North Ammonia System:  Evaporator Cooling Unit EV-9 safety systems as outlined in procedure YOR-OP-034 did not list High suction pressure alarm set point.    (j) North Ammonia System:  Evaporator Cooling Unit EV-10 safety systems as outlined in procedure YOR-OP-035 did not list High suction pressure alarm set point.    (k) North Ammonia System:  Evaporator Cooling Unit EV-11 safety systems as outlined in procedure YOR-OP-036 did not list High suction pressure alarm set point.    (l) North Ammonia System:  Evaporator Cooling Unit EV-12 safety systems as outlined in procedure YOR-OP-037 did not list High suction pressure alarm set point.    (m) North Ammonia System:  Evaporator Cooling Unit EV-1 safety systems as outlined in procedure YOR-OP-038 did not list High suction pressure alarm set point.    (n) North Ammonia System:  V-2 Intercooler safety systems as outlined in procedureYOR-OP-045 did not list level controller and float switch high level alarm and low level alarm set points.    (o) North Ammonia System:  V-3 -40 Recirculator safety systems as outlined in procedure YOR-OP-044 did not list level controller and float switch high level alarm and low level alarm set points.    (p) North Ammonia System: V-4 -10 Recirculator safety systems as outlined in procedure YOR-OP-047 did not list level controller and float switch high level alarm and low level alarm set points.    (q) North Ammonia System:  North Purger ARP-201 safety systems as outlined in operating procedure did not list level controller and float switch alarm set points.    (r) North Ammonia System:  Operation of Wall Tank #1 safety systems as outlined in procedure YOR-OP-026 did not list high suction pressure alarm set point.    (s) North Ammonia System:  Operation of Chiller #1 operating procedure safety systems as outlined in procedure YOR-OP-049 did not list High suction pressure alarm set point.    (t) North Ammonia System:  Operation of Chiller #2 operating procedure safety systems as outlined in procedure YOR-OP-048 did not list High suction pressure alarm set point.

Issued

Jul 23, 2013

Abate by

Jun 2, 2014

Penalty

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

General-duty citation text

29 CFR 1910.119(h)(2)(v):     The employer did not periodically evaluate the performance of contract employers to ensure they are fulfilling their obligations as specified in 29 CFR 1910.119(h)(3).    (a) An evaluation of contractor performance while conducting maintenance and repair activities on the ammonia refrigeration system was not accomplished to ensure the contract employees are following safety rules and established work procedures.

Issued

Jul 23, 2013

Abate by

Aug 15, 2014

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    Inspection frequency of ammonia pumps and motors did not follow established monthly inspection intervals as established by the company's adopted recognized and generally accepted good engineering practices (RAGAGEP), International Institute of Ammonia Refrigeration (IIAR) Bulletin 110 and manufacturers recommendations. The inspections of ammonia pumps, motors and safety controls were not documented as being performed. The following identified ammonia pumps and motors that had not been documented as being performed.    (a) North Ammonia Refrigeration System: East Ammonia Pump, Asset ID ELY0062 did not have inspection and testing documentation available.    (b) North Ammonia Refrigeration System: West Ammonia Pump, Asset ID ELY0063 did not have inspection and testing documentation available.    (c) North Ammonia Refrigeration System: South Ammonia Pump, Asset ID ELY0066 did not have inspection and testing documentation available.    (d) North Ammonia Refrigeration System: North Ammonia Pump, Asset ID ELY0067 did not have inspection and testing documentation available.    (e) North Ammonia Refrigeration System: C-1 Motor, Asset ID ELY0069 did not have inspection and testing documentation available.    (f) North Ammonia Refrigeration System: C-2 Motor, Asset ID ELY0071 did not have inspection and testing documentation available.    (g) North Ammonia Refrigeration System: North Ammonia Detection Panel, Asset ID ELY0129 did not have inspection and testing documentation available.    (h) North Ammonia Refrigeration System: North Ammonia Detection Panel, Asset ID ELY0131 did not have inspection and testing documentation available.    (i) North Ammonia Refrigeration System: North emergency exhaust axial fan, Asset ID ELY0139 did not have inspection and testing documentation available.    (j) South Ammonia Refrigeration System: East Ammonia Pump ARP-201, Asset ID ELY0149 did not have inspection and testing documentation available.    (k) South Ammonia Refrigeration System: West Ammonia Pump ARP-202, Asset ID ELY0150 did not have inspection and testing documentation available.

Issued

Jul 23, 2013

Abate by

Aug 15, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(iv): The employer did not document each inspection and test that had been performed on process equipment.  The documentation did not identify the date of the inpsection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.     Inspection and test documentation for ammonia refrigeration equipment was incomplete. The documentation did not identify the person(s) who performed the inspection or test, the inspection or test performed, results of the inspection or test and corrective actions taken for deficiencies identified during the inspection or test. The following ammonia equipment listed identifies incomplete documentation of inspection and test data.    (a) North Ammonia Refrigeration System, Compressor C-6, Asset ID ELY0033: Inspection documentation did not identify the person(s) who performed the inspection or test, results of the inspection or test and corrective actions taken for deficiencies identified during the inspection or test. Inspection completed on April 8, 2013.    (b) North Ammonia Refrigeration System, Compressor C-7, Asset ID ELY0034: Inspection documentation did not identify the person(s) who performed the inspection or test, results of the inspection or test and corrective actions taken for deficiencies identified during the inspection or test. Inspection completed on April 8, 2013.    (c) North Ammonia System, Compressor C-8, Asset ID ELY0035: Inspection documentation did not identify the person(s) who performed the inspection or test, results of the inspection or test and corrective actions taken for deficiencies identified during the inspection or test. Inspection completed on April 8, 2013.    (d) North Ammonia Refrigeration System, Frigo East Freezer, Asset ID ELY0039: Inspection documentation did not identify the person(s) who performed the inspection or test, results of the inspection or test and corrective actions taken for deficiencies identified during the inspection or test. Inspection completed on April 8, 2013.    (e) South Ammonia Refrigeration System: The -10 Recirculator V-204, Asset ID ELY0034; Inspection documentation did not identify the person(s) who performed the inspection or test, results of the inspection or test and corrective actions taken for deficiencies identified during the inspection or test. Inspection completed on April 8, 2013.

Issued

Jul 23, 2013

Abate by

Jul 1, 2014

Penalty

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

General-duty citation text

29 CFR 1910.119(l)(2): Management of change procedures did not assure that the considerations required by (l)(2)(1) through (l)(2)(v) were addressed prior to any change.    (a) North Ammonia Refrigeration System: A management of change (MOC) was not conducted for 2010 ammonia system expansion. The expansion increased the maximum intended inventory of the ammonia refrigeration system over the 10,000 lbs. threshold quantity (TQ).      (b) North Ammonia Refrigeration System: A management of change (MOC) was not conducted for the 2011 ammonia refrigeration system expansion. Several pieces of equipment were added to the system such as compressors, condensers, and evaporators.     (c) A management of change was not conducted for the north ammonia refrigeration system to assess and consider the impact of the construction and operation of the south ammonia system on the north system. Items to consider in the MOC would be facility siting in relation to the north system; emergency response changes, type of safety systems to be installed, changes in operating procedures. These are some of the impacts to be evaluated in an MOC.

Issued

Jul 23, 2013

Abate by

Aug 29, 2014

Penalty

Initial $3,000 · Current $0 Reduced

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) Periodic inspection of the energy control procedure(s) was not certifed as being accomplished.

Issued

Jul 23, 2013

Abate by

Aug 29, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(3):    The employer did not annually certify that operating procedures were current and accurate.  (a) North Engine Room: Operating procedure for compressor C-9 was last certified in February of 2012. The procedure had not been certified as of May 2013.  (b) North Engine Room: Operating procedure for Compressor C-10 was last certified in February of 2012. The procedure had not been certified as of May 2013.  (c) North Ammonia System: Operating procedure for Evaporative Condenser EC-1A was last certified in March of 2012. The procedure had not been certified as of May 2013.  (d) North Ammonia System: ECHO Lake Foods Overall System Operation Procedure was last certified in July of 2011.  The procedure has not been certified as of May 2013.