OSHA Inspection: HANS KISSLE COMPANY, LLC

Issued

Jun 15, 2017

Abate by

Oct 2, 2017

Penalty

Initial $9,054 · Current $5,400 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 - 9 Creek Brook Drive, Haverhill, MA:    On or about 12/20/2016, the piping and instrumentation diagram for the ammonia refrigeration process did not depict the oil pot in the mechanical room.

Issued

Jun 15, 2017

Abate by

Oct 2, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): Process safety information pertaining to the equipment in the process did not include relief system design and design basis:    (a) Location - 9 Creek Brook Drive, Haverhill, MA:    On or about 12/20/2016, the relief system design and design basis for the ammonia refrigeration system have not been documented.

Issued

Jun 15, 2017

Abate by

Jul 20, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(d)(3)(ii): Compliance with recognized and generally accepted good engineering practices was not documented:  (a) Location - 9 Creek Brook Drive, Haverhill, MA:  On or about 12/20/2016, compliance with recognized and generally accepted good engineering practices (RAGAGEP) was not documented in that the doors of the ammonia refrigeration system mechanical room were not provided with panic-type hardware, were not tight-fitting, and did not open outward. The facility's chosen RAGAGEP, ANSI/IIAR 2-1992, requires that ammonia refrigeration mechanical rooms shall have tight-fitting doors which open outward and are provided with panic type hardware. This requirement is described at Section 4.4.8 of ANSI/IIAR 2 - 1992.

Issued

Jun 15, 2017

Abate by

Feb 1, 2018

Penalty

Initial $9,054 · Current $5,400 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process:      (a) Location - 9 Creek Brook Drive, Haverhill, MA:      On or about 12/20/2016, the hazards of the anhydrous ammonia refrigeration process, such as those associated with the accumulation of noncondensable gases within the process, have not been adequately addressed by the facility through process hazard analysis.

Issued

Jun 15, 2017

Abate by

Feb 1, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not address the consequences of failure of engineering and administrative controls:    (a) Location - 9 Creek Brook Drive, Haverhill, MA:    On or about 12/20/2016, the consequences of failure of engineering and administrative controls associated with the anhydrous ammonia refrigeration process, such as, but not limited to ammonia sensors, pressure relief valves, and daily rounds, have not been adequately addressed by the facility through process hazard analysis.

Issued

Jun 15, 2017

Abate by

Feb 1, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address facility siting:      (a) Location - 9 Creek Brook Drive, Haverhill, MA:      On or about 12/20/2016, facility siting for the anhydrous ammonia refrigeration process, such as location of ammonia refrigeration process equipment and associated piping in proximity to high pressure boilers subjected the equipment to impact in the event of catastrophic high pressure boiler failure, has not been adequately addressed by the facility through process hazard analysis.

Issued

Jun 15, 2017

Abate by

Oct 2, 2017

Penalty

Initial $9,054 · Current $5,400 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(f)(1)(i)(B): Written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information addressing normal operations have not been developed and implemented:    (a) Location - 9 Creek Brook Drive, Haverhill, MA:    On or about 12/20/2016, written procedures for collecting and interpreting ammonia refrigeration system log information have not been developed.

Issued

Jun 15, 2017

Abate by

Oct 2, 2017

Penalty

Initial $9,054 · Current $5,400 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(j)(4)(iv): The documentation of each inspection and test that was performed on the process did not identify the date of the inspection 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:    (a) Location - 9 Creek Brook Drive, Haverhill, MA:    On or about 12/20/2016, the most recent occurrence of ammonia sensor calibration has not been documented.    (b) Location - 9 Creek Brook Drive, Haverhill, MA:    On or about 12/20/2016, documentation of previous occurrences of ammonia sensor calibration does not include the serial number or other identifier of the ammonia sensors calibrated, a description of the calibration performed, and the results of the calibration.    (c) Location - 9 Creek Brook Drive, Haverhill, MA:    On or about 12/20/2016, inspections of refrigerant piping do not result in documentation containing a unique identifier of the piping inspected, a description of the inspection performed, and the results of the inspection.

Issued

Jun 15, 2017

Abate by

Oct 2, 2017

Penalty

Initial $9,054 · Current $5,400 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(l)(1): Procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process have not been implemented:    (a) Location - 9 Creek Brook Drive, Haverhill, MA:    On or about 12/20/2016, procedures to manage changes related to procedures and changes to facilities that affect the ammonia refrigeration system have not been implemented.

Issued

Jun 15, 2017

Abate by

Aug 15, 2017

Penalty

Initial $9,054 · Current $5,400 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(n): An emergency plan was not established for the entire plant in accordance with the provisions of 29 CFR 1910.38:    (a) Location - 9 Creek Brook Drive, Haverhill, MA:    On or about 12/20/2016, the emergency action plan established for the facility does not address procedures for reporting a fire or other emergency, employee rescue or medical duties, and information for who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan as required by 29 CFR 1910.38(c) items 1, 3, and 6.

Issued

Jun 15, 2017

Abate by

Aug 15, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.38(c)(1): The emergency action plan did not include procedures for reporting a fire or other emergency:    (a) Location - 9 Creek Brook Drive, Haverhill, MA:    On or about 12/20/2016, the facility's emergency action plan does not contain procedures for reporting a fire or other emergency.

Issued

Jun 15, 2017

Abate by

Aug 15, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.38(c)(5): The emergency action plan did not include procedures to be followed by employees performing rescue or medical duties:    (a) Location - 9 Creek Brook Drive, Haverhill, MA:    On or about 12/20/2016, the facility's emergency action plan did not include procedures to be followed by employees performing rescue or medical duties, including a prohibition from participating in such activities if applicable.

Issued

Jun 15, 2017

Abate by

Aug 15, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.38(c)(6): The emergency action plan did not include the name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan:    (a) Location - 9 Creek Brook Drive, Haverhill, MA:    On or about 12/20/2016, the facility's emergency action plan does not include the name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan.

Issued

Jun 15, 2017

Abate by

Aug 15, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.120(q)(1): An emergency response plan to handle anticipated emergencies prior to commencement of emergency response operations has not been developed and implemented:    (a) Location - 9 Creek Brook Drive, Haverhill, MA:    On or about 12/20/2016, an emergency response plan has not been developed in order to address anticipated emergencies related to the operation of an industrial ammonia refrigeration system.