OSHA Inspection: THE MONTE VISTA COOPERATIVE

Issued

Sep 25, 2014

Abate by

Feb 28, 2015

Penalty

Initial $1,890 · Current $1,134 Reduced

General-duty citation text

29 CFR 1910.119(d)(2)(i)(A): The employer did not include a block flow diagram or simplified process flow diagram as part of process safety information concerning technology of the process:    a)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not compile and maintain adequate process safety information in order to enable users of the ammonium polyphosphate fertilizer process to identify and understand the hazards of the process.  Specifically, the employer did not provide an adequate block flow or process flow diagram for the process.

Issued

Sep 25, 2014

Abate by

Feb 28, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(2)(i)(B): The employer did not include process chemistry as part of process safety information concerning technology of the process:    a)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not compile and maintain adequate process safety information in order to enable users of the ammonium polyphosphate fertilizer process to identify and understand the hazards of the process.  Specifically, the employer did not provide adequate process chemistry information.

Issued

Sep 25, 2014

Abate by

Feb 28, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer did not include a piping and instrumentation diagram as part of process safety information concerning technology of the process:    a)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not compile and maintain adequate process safety information in order to enable users of the ammonium polyphosphate fertilizer process to identify and understand the hazards of the process.  Specifically, the employer did not provide an adequate piping and instrumentation diagram for the process.

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $1,890 · Current $1,134 Reduced

General-duty citation text

29 CFR 1910.119(e)(6): At least every five (5) years after the completion of the initial process hazard analysis, the process hazard analysis was not updated and revalidated by a team meeting the requirements in paragraph (e)(4) of this section, to assure that the process hazard analysis is consistent with the current process:    a)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not update and revalidate the process hazard analysis that was conducted on May 19, 2009 to evaluate all of the hazards of the process.

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $1,890 · Current $1,134 Reduced

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)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not implement their management of change procedures.  The employer did not provide written information and analysis pertaining to the technical basis for the proposed changes nor the impact of the changes on health and safety.  This documentation was required by the employer's own written management of change procedures.  Changes in equipment and procedures made since the installation of the unit included a change in the power source for the ammonium polyphosphate fertilizer reactor from generator power to plant power, a change in the hose hook up procedure for the reactor operating procedures and the addition of a hot water line from the hot water reservoir to the control room.  The employer did not have any management of change documentation.

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(l)(4): When a change covered by this paragraph resulted in a change in the process safety information required by paragraph (d) of this section, such information was not updated accordingly.    a)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not ensure that process safety information was updated when it was changed.  When the ammonium polyphosphate fertilizer reactor unit switched from generator power to plant power, the employer did not adequately update the process safety information pertaining to the equipment of the process.

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(l)(5): When a change covered by this paragraph resulted in a change in the operating procedures or practices required by paragraph (f) of this section, such procedures or practices were not updated accordingly:        a)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not ensure that operating procedures were updated when they were changed.  Operating procedures written on July 6, 2009, and September 21, 2011, stated that the hose is to be attached to the ammonia piping and run under the rail tracks and connected to the reactor system each time the fertilizer reactor is operated.  These hoses actually remain attached and connecting them to the ammonia piping is not done each time the reactor is operated.

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $3,150 · Current $1,890 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not implement written procedures to maintain the on-going integrity of process equipment:      a)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not fully develop and implement their mechanical integrity procedures for the anhydrous ammonia storage tank, the ammonium polyphosphate reactor and the associated piping.  The employer did not explain the mechanical integrity program's basis in recognized and generally accepted good engineering practices and did not follow through on their own quarterly and daily deadlines for inspection.  Some equipment including piping and emergency shutoff valves were observed to be in poor condition.

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(4)(ii): Inspection and testing procedures did not follow recognized and generally accepted good engineering practices:    a)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not follow recognized and generally accepted good engineering practices for the anhydrous ammonia storage tank, the ammonium polyphosphate reactor and the associated piping.  Inspections of much of the equipment were limited to visual inspections that were not compared against a standard.  Equipment deficiencies were observed which included rusted, unpainted piping sections and broken emergency shutoff valves called "Snappy Joes".

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $0 · Current $0

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)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not follow recognized and generally accepted good engineering practices for the anhydrous ammonia storage tank, the ammonium polyphosphate reactor and the associated piping.  Inspections did not occur frequently enough to maintain equipment within an acceptable state.  The most recent quarterly inspection was documented to have occurred on July 27, 2013.  Equipment deficiencies were observed which included rusted, unpainted piping sections and broken emergency shutoff valves called "Snappy Joes".

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): Equipment deficiencies. The employer did not correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means were taken to assure safe operation:    a)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not correct equipment deficiencies in a timely manner for the anhydrous ammonia storage tank, the ammonium polyphosphate reactor, and associated equipment.  Equipment deficiencies were observed which included rusted, unpainted piping sections and broken emergency shutoff valves called "Snappy Joes".

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $1,890 · Current $1,134 Reduced

General-duty citation text

29 CFR 1910.119(k)(1): The employer did not issue a hot work permit for hot work operations conducted on or near a covered process:    a)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not issue hot work permits for hot work operations.  On August 10, 2013, an employee performed hot work (torch cut hole in the water reservoir) above the ammonium polyphosphate reactor vessel.  During this operation a hot work permit was not issued and a fire watch/attendant was not provided.

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $1,890 · Current $1,134 Reduced

General-duty citation text

29 CFR 1910.119(m)(1): The employer shall investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace:      a)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not investigate incidents which could have resulted in the release of anhydrous ammonia.  The employer stated that a pressure relief/"pop off" valve was activated and had to be replaced during a loading process at the main anhydrous storage tank a few years ago.  The employer stated that a formal investigation was not conducted or recorded.  The employer was unable to remember or explain the cause of the valve activation.

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $1,890 · Current $1,134 Reduced

General-duty citation text

29 CFR 1910.119(o)(1): The employer did not verify that the procedures and practices developed under the standard were being followed:    a)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not adequately verify that the procedures and practices developed under the process safety management standard were being followed.  Compliance audits were completed on April 20, 2014, and May 24, 2013, however these audits inaccurately verified compliance.

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.    a)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not complete the 'corrective action" portion of their April 20, 2014 and May 24, 2013 compliance audits.

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $1,890 · Current $1,134 Reduced

General-duty citation text

29 CFR 1910.119(n): The employer did not establish an emergency plan for the entire plant in accordance with the provisions of 29 CFR 1910.38:    a)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not establish an emergency action plan for the facility.

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $1,890 · Current $1,134 Reduced

General-duty citation text

29 CFR 1910.151(c):  Where employees were exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use:      a)  On or about June 11, 2014, and at times prior, fertilizer plant employees were exposed to anhydrous ammonia while they worked at and around the ammonium polyphosphate reactor without suitable eyewash facilities within the immediate work area.

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(h)(2)(v): The employer did not periodically evaluate the performance of contract employers in fulfilling their obligations as specified in paragraph (h)(3) of this section:    a)  On or about June 11, 2014, and at times prior, employees were exposed to the hazards of ammonia exposure because the employer did not conduct periodic evaluations of contractors, such as hauling and delivery contractors, to ensure that they understood the hazards of the anhydrous ammonia storage tank and/or the ammonium polyphosphate reactor and that they could demonstrate their ability to safely work with and around the system.

Issued

Sep 25, 2014

Abate by

Dec 13, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.146(c)(2): The employer did not inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces:    a)  On or about June 11, 2014, and at times prior, employees were exposed to hazardous atmospheres or engulfment because the employer did not maintain danger/confined space signs on the ammonium polyphosphate product tank at the reactor unit.