OSHA Inspection: SMITH DAIRY PRODUCTS COMPANY INC

Issued

Jul 10, 2013

Abate by

Aug 14, 2013

Penalty

Initial $4,250 · Current $2,550 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F):  Process safety information pertaining to the equipment did not include the design codes and standards employed:      The process safety information did not include the design codes and standards utilized for the design of the emergency shutdown system and the compressor cutouts including the high level, low and high pressure discharge, oil pressure and temperature interlocks.

Issued

Jul 10, 2013

Abate by

Aug 14, 2013

Penalty

Initial $4,250 · Current $2,550 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii):  The employer did not document that equipment complied with recognized and generally accepted good engineering practices:      Relief header A which is connected to pressure safety relief valves in the milk process engine room discharges to an area on the roof where employees are required to work on a regular basis to monitor the operation of the refrigeration system. Employees working in the area can be exposed to high levels of ammonia in the event that a relief valve activates.    Refer to ANSI/ASHRAE,  Safety Standard for Ammonia Refrigeration Systems 15, which states in section 9.7.8 that discharge must be 15 feet above the working surface.

Issued

Jul 10, 2013

Abate by

Aug 14, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3)(v):  The process hazard analysis did not address the hazards of facility siting:     The process hazard analysis done in 2011 did not address the hazard of discharge of ammonia near areas where employees work.  Relief header A which is connected to pressure safety relief valves in the milk process engine room discharges to an area on the roof where employees are required to work on a regular basis to monitor the operation of the refrigeration system. Employees working in the area can be exposed to high levels of ammonia in the event that a relief valve activates.     Refer to ANSI/ASHRAE,  Safety Standard for Ammonia Refrigeration Systems 15, which states in section 9.7.8 that discharge must be 15 feet above the working surface:

Issued

Jul 10, 2013

Abate by

Aug 14, 2013

Penalty

Initial $4,250 · Current $2,550 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(B):  The employer's written operating procedures covering safety and health considerations did not address the precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment:       The procedures developed for periodic oil draining from the ammonia refrigeration system did not include a determination on the need for respirators to protect employees from exposure to ammonia during the oil draining procedure.

Issued

Jul 10, 2013

Abate by

Aug 14, 2013

Penalty

Initial $4,250 · Current $2,550 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 mechanical integrity of process equipment:       No specific procedures were developed to inspect ammonia piping and vessels.  Employees are told to look for corrosion and leaks but no written guidance is provided for exactly what to look for during inspections of insulated and uninsulated equipment.

Issued

Jul 10, 2013

Abate by

Aug 14, 2013

Penalty

Initial $4,250 · Current $2,550 Reduced

General-duty citation text

29 CFR 1910.119(k)(2):  The hot work permit did not document that the fire prevention and protection requirements in 29 CFR 1910.252(a) had been implemented prior to beginning the hot work operations:      Hot work permits utilized for work done on 5/29, 31 and 6/5/13 were not completed in that the, "required precaution checklist", was not filled out to document that the protection requirements were implemented.

Issued

Jul 10, 2013

Abate by

Aug 30, 2013

Penalty

Initial $3,400 · Current $2,550 Reduced

General-duty citation text

29 CFR 1910.120(q)(2)(xi):  The emergency response plan did not address, to the extent not addressed elsewhere,  PPE and emergency equipment:       The plan for response to ammonia leaks states that Self Contained Breathing Apparatus (SCBA) will be used during the response, but medical reports for at least two responders state that they are not medically permitted to use SCBAs.  The plan should address PPE for employees who respond but are not cleared to use SCBAs.

Issued

Jul 10, 2013

Abate by

Aug 30, 2013

Penalty

Initial $4,250 · Current $0 Reduced

General-duty citation text

29 CFR 1910.134(f)(1): The employer did not ensure that employees using a tight-fitting facepiece respirator pass an  appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT) as stated in 29 CFR 1910(f):       The plan for response to ammonia leaks states that Self Contained Breathing Apparatus (SCBA) will be used during the response.  A QNFT is required for this respirator but no fit testing was done for employees who respond to leaks.

Issued

Jul 10, 2013

Abate by

Aug 14, 2013

Penalty

Initial $4,250 · Current $2,550 Reduced

General-duty citation text

29 CFR 1910.120(q)(8)(i):  Employees who were trained in accordance with 29 CFR 1910.120(q)(6) did not receive annual refresher training of sufficient content and duration to maintain their competencies or did not demonstrate competency in those areas at least yearly:       Hazardous materials technician refresher training has not been provided for employees in 2012 or 2013 by the day of the inspection. Training is required on an annual basis.