OSHA Inspection: YUMA ETHANOL LLC

Issued

Sep 9, 2016

Abate by

Nov 29, 2016

Penalty

Initial $1,817 · Current $1,363 Reduced

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) Yuma Ethanol, LLC, at 38480 CR H, Yuma, CO 80759:  On and before March 17, 2016 the employer did not  periodically evaluate the performance of contract employers in fulfilling their obligations as specified in paragraph (h)(3) of section 1910.119(h).  This condition exposed employees and contractor's to chemical and burn hazards.    Abatement Note:  29 CFR 1910.119(h)(3) provides:    Contract Employer Responsibilities:    (i)  The contract employer shall assure that each contract employee is trained in the work practices necessary to safely perform his/her job.    (ii)  The contract employer shall assure that each contract employee is instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the process, and the applicable provisions of the emergency action plan.    (iii)  The contract employer shall document that each contract employee has received and understood the training required by this paragraph.  The contract employer shall prepare a record which contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training.    (iv)  The contract employer shall assure that each contract employee follows the safety rules of the facility including the safe work practices required by paragraph (f)(4) of this section.    (v)  The contract employer shall advise the employer of any unique hazards presented by the contract employer's work, or of any hazards found by the contract employer's work.

Issued

Sep 9, 2016

Abate by

Nov 29, 2016

Penalty

Initial $2,423 · Current $1,818 Reduced

General-duty citation text

29 CFR 1910.119(e)(2): The employer did not use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed:    (i)  What-If  (ii)  Checklist  (iii)  What-If/Checklist  (iv)  Hazard and Operability Study (HAZOP)  (v)  Failure Mode and Effects Analysis (FMEA)  (vi)  Fault Tree Analysis or  (vii)  An appropriate equivalent methodology    a) Yuma Ethanol, LLC, at 38480 CR H, Yuma, CO 80759:  On and before March 17, 2016 the employer did not use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed in the 2007 Process Hazard Analysis (PHA). This condition exposed employees and contractor's to chemical and burn hazards.

Issued

Sep 9, 2016

Abate by

Nov 29, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(3): The process hazard analysis did not address:    (ii)  The identification of any previous incident which had a likely potential for catastrophic consequences in the work-place  (iii)  Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases.  (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors)  (iv)  Consequences of failure of engineering and administrative controls  (v)  Facility siting  (vi)  Human factors; and  (vii)  A qualitative evaluation of a arrange of the possible safety and health effects of failure of controls on employees in the workplace.    a) Yuma Ethanol, LLC, 38480 CR H, Yuma, CO 80759:  On and before March 17, 2016 the employer did not address the items listed above in the 2007 process hazard analysis (PHA).  The PHA addressed the process description, the review methodology, and the hazards associated with the piping and instrumentation diagrams (P & ID's).  However the PHA was deficient in that it did not address all of the items stated above.  This condition exposed employees and contractor's to chemical and burn hazards.

Issued

Sep 9, 2016

Abate by

Nov 29, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions:    a) Yuma Ethanol, LLC, at 38480 CR H, Yuma, CO 80759:  On and before March 17, 2016, regarding the 2007 process hazard analysis (PHA), the employer did not establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.  This condition exposed employees and contractor's to chemical and burn hazards.

Issued

Sep 9, 2016

Abate by

Nov 29, 2016

Penalty

Initial $3,634 · Current $2,726 Reduced

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) Yuma Ethanol, LLC, at 38480 CR H, Yuma, CO: On and before March 17, 2016, the employer failed to follow Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) for inspection and testing of equipment covered by process safety management. A system utilizing approximately 18,000 gallons (95,026 pounds) of anhydrous ammonia was used to alter the pH of corn slurry within a process tank inside of the production building. Carbon steel piping was used to move the anhydrous ammonia into the slurry tank. The employer did not perform inspections of the process vessel in accordance with the selected RAGAGEP. This would have required that visibly damaged insulation be removed to inspect the underlying vessel for damage resulting from moisture. This is not consistent with the employers internal Inspection & Test (I&T) procedures, or API 653 as the employer specified RAGAGEP. This condition exposed employees to a chemical hazard.    (b) Yuma Ethanol, LLC, at 38480 CR H, Yuma, CO: On and preceding 4/7/2016, the employer failed to follow Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) for inspection and testing of equipment covered by process safety management. A system utilizing approximately 18,000 gallons (95,026 pounds) of anhydrous ammonia was used to alter the pH of corn slurry within a process tank inside of the production building. Carbon steel piping was used to direct the anhydrous ammonia into the slurry tank. The piping service class was categorized as Class 1. The employer did not perform inspections of the process piping in accordance with the selected RAGAGEP. This would have required that visibly damaged pipe insulation be removed to inspect the underlying piping for areas of damage resulting from moisture. This is not consistent with the employers internal Inspection & Test (I&T) procedures, or API 570 as the employer specified RAGAGEP. This condition exposed employees to a chemical hazard.

Issued

Sep 9, 2016

Abate by

Nov 29, 2016

Penalty

Initial $3,634 · Current $2,726 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The employer's frequency of inspections and tests of process equipment was not consistent with applicable manufacturer's recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience:    (a) Yuma Ethanol, LLC, at 38480 CR H, Yuma, CO: On and before March 17, 2016, the employer did not ensure that the frequency of inspections and tests of process equipment was consistent with applicable manufacturer's recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience. A system utilizing approximately 18,000 gallons (95,026 pounds) of anhydrous ammonia was used to alter the pH of corn slurry within a process tank inside of the production building. This process is covered by process safety management. Carbon steel piping in the production building was used to direct the anhydrous ammonia into the slurry tank. The piping service class was categorized as Class 1. The employer did not perform inspections of the process piping at a frequency in accordance with the selected Recognized and Generally Accepted Good Engineering Practices (RAGAGEP). This would have required that thickness testing of the piping was conducted every 5 years. This is not consistent with the employers internal Inspection & Test (I&T) procedures, or API 570 as the employer specified RAGAGEP. This condition exposed employees to a chemical hazard.

Issued

Sep 9, 2016

Abate by

Nov 29, 2016

Penalty

Initial $2,423 · Current $1,818 Reduced

General-duty citation text

29 CFR 1910.119(n):  The employer did not 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 did not include procedures for handling small releases. Employers covered under this standard may be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120 (a), (p) and (q):    a) Yuma Ethanol, LLC, at 38480 CR H, Yuma, CO 80759:  On and before March 17, 2016 the employer did not establish and implement an emergency action plan in accordance with 29 CFR 1910.38(d), Employee Alarm System.  The alarm system did not provide distinctive signals for incidental versus other chemical releases.  In addition, the emergency action plan did not adequately define procedures for handling small releases, including appropriate pre-planning for procedures, training, and equipment.  This condition exposed employees and contractor's to chemical and burn hazards.

Issued

Sep 9, 2016

Abate by

Nov 29, 2016

Penalty

Initial $3,634 · Current $2,726 Reduced

General-duty citation text

29 CFR 1910.132(a): Protective equipment was not used when necessary whenever hazards capable of causing injury and impairment were encountered:    a) Yuma Ethanol, LLC, at 38480 CR H, Yuma, CO 80759:  On and before March 9, 2016 the employer did not ensure that each affected employee use appropriate personal protective equipment (PPE) to protect the employees from being burned by hot slurry.  Two employees were burned by hot slurry while changing out a slurry strainer when a drain valve was left open.  This condition exposed employees to chemical and burn hazards.    Abatement note:  Appropriate PPE includes the use of fire retardant clothing, gloves, safety glasses, and a face shield.

Issued

Sep 9, 2016

Abate by

Nov 29, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.132(f)(2): Each affected employee did not demonstrate an understanding of the training specified in paragraph (f)(1) of this section, and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE:    a) Yuma Ethanol, LLC, at 38480 CR H, Yuma, CO 80759:  On and before March 9, 2016 the employer did not ensure that each employee could demonstrate an understanding of training in that PPE was not properly used during slurry strainer maintenance operations.   Two employees were burned when a drain valve was left open while changing out a slurry strainer.  This condition exposed employees to chemical and burn hazards.

Issued

Sep 9, 2016

Abate by

Nov 29, 2016

Penalty

Initial $1,817 · Current $1,363 Reduced

General-duty citation text

29 CFR 1910.141(a)(3)(ii): The floor of every workroom was not maintained, so far as practicable, in a dry condition:    a) Yuma Ethanol, LLC, at 38480 CR H, Yuma, CO 80759:  On and before March 17, 2016 the employer did not ensure that the floors of every workplace were maintained, as far as practicable, in a dry condition.  This condition exposed employees and contractor's to chemical and burn hazards.

Issued

Sep 9, 2016

Abate by

Nov 29, 2016

Penalty

Initial $3,634 · Current $2,726 Reduced

General-duty citation text

29 CFR 1910.147(d)(6): Prior to starting work on machines or equipment that had been locked out or tagged out, the authorized employee did not verify that isolation and de-energization of the machine or equipment had been accomplished:    a) Yuma Ethanol, LLC, at 38480 CR H, Yuma, CO 80759:  On and before March 9, 2016 the employer did not ensure that prior to changing out the slurry strainer, the production manager did not verify that the slurry drain valve on the North slurry strainer was isolated and de-energized for the release of slurry or 180 corn mash.  This condition exposed employees to chemical and burn hazards.