OSHA Inspection: CEDAR GROVE WAREHOUSING LLC

Issued

Apr 26, 2017

Penalty

Initial $6,338 · Current $3,486 Reduced

General-duty citation text

29 CFR 1910.119(c)(3): Employers shall provide to employees and their representatives access to process hazard analyses and to all other information required to be developed under this standard.   a)  On or about December 20, 2016, the process safety management programs, system information and documentation for the ammonia refrigeration system located at 802 South Street, Plymouth, WI were not available. The employer had not gathered and organized the process safety management programs, system information and documentation developed by the previous facility owner.

Issued

Apr 26, 2017

Abate by

Aug 24, 2017

Penalty

Initial $6,338 · Current $3,486 Reduced

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) On or about January 11, 2017, the pressure relief line pressure gauge associated with Compressor 29 was misidentified as RL-AF when the P&ID R104 identified the pressure gauge as RL-AE.    b) On or about January 11, 2017, the filter, associated with Compressor 29 and identified on P&ID R104 as LQ-DY, was missing its identification tag.    c) On or about January 11, 2017, the drain valve, associated with Compressor 29 and identified on P&ID R104 as LQ-DV-C, was missing its identification tag.    d) On or about January 11, 2017, the drain valve, associated with Compressor 29 and identified on P&ID R104 as LQ-DN-C, was missing its identification tag.    e) On or about January 11, 2017, a valve, with the identification tag CD-O, on the 1 inch High Pressure Liquid (HPL) pipe section between the sight glass LQ-CD and pump LQ-CC was not indicated on P&ID R104. The 1 inch High Pressure Liquid (HPL) pipe section is associated with Compressor 29.    f) On or about January 11, 2017, the pressure relief line pressure gauge associated with Compressor 28 was misidentified as RL-AF when the P&ID R104 identified the pressure gauge as RL-AE.    g) On or about January 11, 2017, the drain valve, associated with Compressor 28 and identified on P&ID R104 as LQ-DZ-C, was missing its identification tag.    h) On or about January 11, 2017, the filter, associated with Compressor 28 and identified on P&ID R104 as LQ-DM, was missing its identification tag.    i) On or about January 11, 2017, the drain valve, associated with Compressor 28 and identified on P&ID R104 as LQ-DF-O, was missing its identification tag.    j) On or about January 11, 2017, the pressure gauge, associated with Compressor 28 and identified on P&ID R104 as LQ-CG, was missing its identification tag.    k) On or about January 11, 2017, the pressure relief line pressure gauge associated with Compressor 30 was misidentified as RL-AF when the P&ID R104 identified the pressure gauge as RL-AE.    l)  On or about January 11, 2017, the valve, associated with Compressor 30 and identified on P&ID R104 as SU-BA-O, was missing its identification tag.    m) On or about January 11, 2017, the filter, associated with Compressor 30 and identified on P&ID R104 as LQ-DY, was missing its identification tag.    n) On or about January 11, 2017, the 1 inch High Pressure Liquid (HPL) pipe section increases in diameter to 2 inches between valve LQ-CE-O and the T-intersection pipe section containing float valve B-ER-MIS-104-LQ-CG-R which is not indicated on P&ID R104. The 1 inch HPL pipe section is associated with Compressor 30.    o) On or about January 11, 2017, the sight gauge, associated with Compressor 30 and identified on P&ID R104 as LQ-CD, was misidentified as CD-O.    p) On or about January 11, 2017, the drain valve, associated with Compressor 30 and identified on P&ID R104 as LQ-DQ-O, was missing its identification tag.    q) On or about January 11, 2017, the pressure indicator, associated with Compressor 30 and identified on P&ID R104 as LQ-CC, was misidentified as CC.    r) On or about January 11, 2017, the pressure indicator, associated with Compressor 30 and identified on P&ID R104 as LQ-CG, was missing its identification tag.    s) On or about January 11, 2017, P&ID R104 did not indicate a pipe section connecting 3/4 inch High Stage Suction (HSS) pipe section containing valve SU-BE-O to 1/2 inch High Pressure Liquid (HPL) pipe section containing expansion valve LQ-CB-O. The interconnected pipe sections are associated with Compressor 21.    t) On or about January 11, 2017, the valve, associated with Compressor 21 and identified on P&ID R104 as SU-CA-O, was missing its identification tag.    u) On or about January 11, 2017, the temperature indicator, associated with Compressor 21 and identified on P&ID R104 as HG-AK, was missing its identification tag.    v) On or about January 12, 2017, P&ID R104 did not indicate a second valve on a pipe section containing valve B-ER-MIS-104-SU-BC-C, that use to connect a chiller to the 4 inch High Stage Suction (HSS) pipe section. The second valve did not have an identification tag.     w) On or about January 11, 2017, the valve, associated with the High Pressure Vessel and identified on P&ID R111 as LQ-CN-C, was missing its identification tag.    x) On or about January 11, 2017, the valve, associated with the High Pressure Vessel and identified on P&ID R111 as LQ-CM-C, was missing its identification tag.    y) On or about January 11, 2017, P&ID R111 did not indicate a drain valve on the pressure relief header associated with the High Pressure Receiver. The drain valve did not have an identification tag.    z) On or about January 11, 2017, the valve, associated with the Evaporative Condenser #1 and identified on P&ID R111 as HG-AD-O, was missing its identification tag.    aa) On or about January 11, 2017, the valve, associated with the Evaporative Condenser #3 and identified on P&ID R111 as HG-AH-O, was missing its identification tag.     bb) On or about January 11, 2017, the valve, associated with the Evaporative Condenser #2 and identified on P&ID R111 as HG-AA-O, was missing its identification tag.    cc) On or about January 11, 2017, the valve, associated with the Evaporative Condenser #4 and identified on P&ID R111 as HG-AG-O, was missing its identification tag.    dd) On or about January 11, 2017, the valve, associated with the Evaporative Condenser #4 and identified on P&ID R111 as HG-AD-O, was identified as HG-AA-O. A second nearby valve, associated with Evaporative Condenser #4 and identified on P&ID R111 as HG-AA-O, was identified as HG-AD-O.    ee) On or about January 12, 2017, the valve, associated with the Evaporator #242 and identified on P&ID R109 as LQ-CB-R, was identified as CH-R.    ff) On or about January 12, 2017, the valve, associated with the Oil Pot LQ-CF and identified on P&ID R108 as LQ-CE-O, was missing its identification tag.    gg) On or about January 12, 2017, the valve, associated with the Oil Pot LQ-CF and identified on P&ID R108 as HG-AA-C, was missing its identification tag.    hh) On or about January 12, 2017, the valve, associated with the Oil Pot LQ-CF and identified on P&ID R108 as LQ-CK-R, was identified as LQ-CK.    ii) On or about January 12, 2017, the pressure relief valve, associated with the L.P. Receiver 54 and identified on P&ID R102 as RL-AD-C, was missing its identification tag.    jj) On or about January 12, 2017, the pressure gauge for pressure relief valve RL-AD-C, associated with the L.P. Receiver 54 and identified on P&ID R102 as RL-AE-C, was identified as RL-AF-C.    kk) On or about January 12, 2017, P&ID R102 indicated there was a Check Valve LQ-CQ-O, associated with the L.P. Receiver 54, which was not located on the ammonia refrigeration system.    ll) On or about January 12, 2017, the stop valve, associated with the L.P. Receiver 54 transfer pump and identified on P&ID R102 as LQ-CW-O, was missing its identification tag.    mm) On or about January 12, 2017, the transfer pump, associated with the L.P. Receiver 54 and identified on P&ID R102 as LQ-DF, was missing its identification tag.    nn) On or about January 12, 2017, the components of the sight glass, associated with the Liq. Recirc. Receiver #53 and identified on P&ID R102 as TR OFF, TR ON, and HLCO were missing their identification tags.    oo) On or about January 12, 2017, a valve, associated with the Liq. Recirc. Receiver #53 and identified on P&ID R102 as LQ-CW-O, was missing its identification tag.    pp) On or about January 12, 2017, a valve, associated with the Liq. Recirc. Receiver #53 and identified on P&ID R102 as SU-BV-C, was identified as SU-BV-O.    qq) On or about January 12, 2017, P&ID R102 did not indicate a drain valve and pressure gauge on the 3 inch High Temperature Recirculated Liquid (HTRL) pipe section between valve LQ-CP-O and the T-intersection with the pipe section containing Valve LQ-CN-O which was associated with the Liq. Recirc. Receiver #53. The drain valve and pressure gauge did not have identification tags.    rr) On or about January 12, 2017, P&ID R102 indicated there was a Check Valve LQ-CU-O, associated with the Liq. Recirc. Receiver #53, which was not located on the ammonia refrigeration system.    ss) On or about January 12, 2017, P&ID R102 did not indicate a T-intersection pipe section with valve LQ-CL-O on the 3/4 inch Liquid Transfer pipe section which was associated with the Liq. Recirc. Receiver #53.    tt) On or about January 12, 2017, a valve, associated with the L.P. Receiver #56 and identified on P&ID R103 as LQ-DP-C, was missing its identification tag.    uu) On or about January 12, 2017, a transfer pump, associated with the L.P. Receiver #56 and identified on P&ID R103 as LQ-CK, was missing its identification tag.    vv) On or about January 12, 2017, a valve, associated with Liq. Recirc. Receiver #57 and identified on P&ID R103 as LQ-CG-C, was missing its identification tag.    ww) On or about January 12, 2017, a valve, associated with Liq. Recirc. Receiver #57 and identified on P&ID R103 as LQ-CY-O, was missing its identification tag.    xx) On or about January 12, 2017, a pressure indicator, associated with Liq. Recirc. Receiver #57 and identified on P&ID R103 as LQ-DN, was missing its identification tag.    yy) On or about January 12, 2017, a valve, associated with Liq. Recirc. Receiver #57 and identified on P&ID R103 as LQ-DM-O, was missing its identification tag.    zz) On or about January 12, 2017, a pressure regulator, associated with Liq. Recirc. Receiver #57 and identified on P&ID R103 as A2BK, was missing its identification tag.    aaa) On or about January 12, 2017, a drain, associated with Liq. Recirc. Receiver #57 and identified on P&ID R103 as LQ-DP-O, was missing its identification tag.    bbb) On or about January 12, 2017, a valve, associated with Liq. Recirc. Receiver #57 and identified on P&ID R103 as LQ-DK-C, was missing its identification tag.    ccc) On or about January 12, 2017, a valve, associated with Liq. Recirc. Receiver #57 and identified on P&ID R103 as LQ-DY-C, was missing its identification tag.    ddd) On or about January 12, 2017, an angle stop valve, associated with Liq. Recirc. Receiver #57 and identified on P&ID R103 as LQ-DA-O, was identified as LQ-DA-C.    eee) On or about January 12, 2017, a valve, associated with Liq. Recirc. Receiver #57 and identified on P&ID R103 as LQ-CP-C, was missing its identification tag.    fff) On or about January 12, 2017, a pressure regulator, associated with Liq. Recirc. Receiver #57 and identified on P&ID R103 as A2BK, was missing its identification tag.    ggg) On or about January 12, 2017, a drain, associated with Liq. Recirc. Receiver #57 and identified on P&ID R103 as LQ-CS-R, was missing its identification tag.    hhh) On or about January 12, 2017, P&ID R103 indicated a pipe section with Valve LQ-CT-C, associated with Liq. Recirc. Receiver #57 North Pump LQ-CM which was not located on the ammonia refrigeration system.    iii) On or about January 12, 2017, P&ID 103 indicated a pipe section containing Valve LQ-CQ-O and Pressure Indicator LQ-CR intersected the 2 inch High Temperature Recirculated Liquid (HTRL) between Drain LQ-CS-R and a T-intersection with a pipe section containing Pressure Indicator RL-AH-C. The pipe section containing Valve LQ-CQ-O and Pressure Indicator LQ-CR was located on a different 2 inch HTRL pipe section between North Pump LQ-CN and a T-intersection with a pipe section containing Drain LQ-CS-R on the ammonia refrigeration system.    jjj) On or about January 12, 2017, a valve, associated with Liq. Recirc. Receiver #57 and identified on P&ID R103 as LQ-CA-O, was missing its identification tag.    kkk) On or about January 12, 2017, P&ID 103 did not indicate a self-closing valve on a pipe section, associated with Liq. Recirc. Receiver #57, between Valve LQ-CE-C and Valve LQ-CZ-C. The self-closing valve did not have an identification tag.    lll) On or about January 12, 2017, a component of Sight Glass LQ-DX, associated with Liq. Recirc. Receiver #57, identified on P&ID R103as LQ-DV was missing its identification tag.

Issued

Apr 26, 2017

Penalty

Initial $6,338 · Current $3,486 Reduced

General-duty citation text

29 CFR 1910.119(j)(2): Written procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment.  a)  On or about December 20, 2016, the employer had not developed and implemented written procedures to maintain the on-going integrity of the ammonia refrigeration system.

Issued

Apr 26, 2017

Abate by

Jun 23, 2017

Penalty

Initial $6,338 · Current $3,486 Reduced

General-duty citation text

29 CFR 1910.120(q)(2)(ii): The employer shall develop an emergency response plan for emergencies which shall address, as a minimum, the following to the extent that they are not addressed elsewhere: Personnel roles, lines of authority, training, and communication.    a) On or about December 20, 2016, the employer had not identified and trained personnel to assume the role of on-scene incident commander when the Ammonia Supervisor would investigate an ammonia leak source or take actions to control an ammonia leak.    b) On or about December 20, 2016, the employer had not identified and trained personnel to work with the Ammonia Supervisor as a Hazardous Material Technician within a buddy system.    c) On or about December 20, 2016, the employer had not identified and trained personnel to act as back up personnel for employees working as a Hazardous Material Technician.    d) On or about December 20, 2016, the employer had not identified, assigned, and trained personnel to account for all personnel after an evacuation or relocation due to an ammonia release.

Issued

Apr 26, 2017

Penalty

Initial $6,338 · Current $3,486 Reduced

General-duty citation text

29 CFR 1910.134(e)(1): General. The employer shall provide a medical evaluation to determine the employee's ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace. The employer may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator.  a) On or about December 20, 2016, maintenance personnel required to wear full face cartridge respirators while investigating ammonia leaks and perform ammonia refrigeration system pipe breaking maintenance tasks were not medically evaluated.

Issued

Apr 26, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(f)(2): The employer shall ensure that an employee using a tight-fitting facepiece respirator is fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter.  a)  On or about December 20, 2016, maintenance personnel required to wear a full face cartridge respirator to investigate ammonia leaks and perform ammonia refrigeration system pipe breaking maintenance tasks had not been fit tested.

Issued

Apr 26, 2017

Abate by

Jun 23, 2017

Penalty

Initial $6,338 · Current $3,486 Reduced

General-duty citation text

29 CFR 1910.146(c)(4): If the employer decides that its employees will enter permit spaces, the employer shall develop and implement a written permit space program that complies with this section. The written program shall be available for inspection by employees and their authorized representatives.     a)  On or about January 20, 2017, the employer's written Confined Space Entry Program had deficiencies related to key elements of a PRCS Program, such as but not limited to;   1.     Program states that employees can enter Permit Required Spaces, but the employer has not provided training to perform Permit Required Confined Space entries.    2.     The declassification procedures for entering Condenser Tower 8 does not give specific instructions for verifying and documenting that the hazards have been eliminated, the specific work tasks that can be performed using the procedure, or methods for isolating or preventing the release of ammonia into the space.   3.     The program did not include Air Handler Units located on the second and third floors as permit required confined spaces.

Issued

Apr 26, 2017

Abate by

Jun 23, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.146(g)(1): The employer shall provide training so that all employees whose work is regulated by this section acquire the understanding, knowledge, and skills necessary for the safe performance of the duties assigned under this section.    a) On December 20, 2016, the employer had not provided training for their employees on when it is appropriate and the methods to be used to reclassify permit required confined spaces, such as, but not limited to the Condenser Towers, the two 2nd floor Air Handler Units (AHU), the two 3rd floor Air Handler Units (AHU), and four elevator shafts was not documented.

Issued

Apr 26, 2017

Penalty

Initial $6,338 · Current $3,486 Reduced

General-duty citation text

29 CFR 1910.1001(j)(3)(i): Building and facility owners shall determine the presence, location, and quantity of ACM and/or PACM at the work site. Employers and building and facility owners shall exercise due diligence in complying with these requirements to inform employers and employees about the presence and location of ACM and PACM.  a) On or about December 20, 2016, the employer did not know where asbestos containing material (ACM) and/or presumed asbestos containing material (PACM) was located in the facility.

Issued

Apr 26, 2017

Penalty

Initial $3,802 · Current $2,091 Reduced

General-duty citation text

29 CFR 1910.1200(h)(3)(i): Employee training shall include at least: methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.).  a)  On or about December 20, 2017, the employer had not trained the warehouse employees on the continuous monitoring devices, visual observations and odor characteristics for identifying ammonia leaks and releases.

Issued

Apr 26, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(h)(3)(ii): Employee training should include at least: the physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area.  a) On or about December 20, 2017, the employer had not provided specific training on the characteristics and hazards of ammonia.

Issued

Apr 26, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(g)(3): Training documentation. The employer shall ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The employer shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.  a) On or about December 20, 2016, the employer had not documented employees performing ammonia refrigeration system operating procedures had received training and obtained the needed knowledge, skills and abilities to carry out their assigned work tasks in a safe manner.

Issued

Apr 26, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(f)(6)(ii): Except as provided in 29 CFR 1910.1200(f)(7) and 29 CFR 1910.1200(f)(8), the employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals and which, in conjunction with the other information immediately available to employees under the hazard communication program, would provide employees with the specific information regarding the physical and health hazards of the hazardous chemical  a) On or about December 20, 2016, the water softener salt tank, located in the Boiler Room, was not labeled with the identity and hazards of its contents.