OSHA Inspection: EDDY PACKING CO., INC.

Issued

Jul 14, 2017

Abate by

Aug 30, 2017

Penalty

Initial $5,432 · Current $3,150 Reduced

General-duty citation text

29 CFR 1910.119(d): Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.    On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not have process safety information such as manufacturers data report for the pressure vessel, Low Stage Recirculator V-02 (Eddypack-P&ID02 Revision #3).

Issued

Jul 14, 2017

Abate by

Aug 2, 2017

Penalty

Initial $12,675 · Current $7,462 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams (P&ID) were not accurate.     On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not ensure that piping and instrument diagrams (P&IDs) were accurate.  The P&IDs were not accurate as the following but not limited to.   a.   EDDYPACK-P&ID01, Rev. #4 (Engine Room) and EDDYPACK-P&ID02, Rev. #3 (Engine Room). These P&IDs did not include a third vent/stack line (yellow one) for anhydrous ammonia.     b.   EDDYPACK-P&ID04, Rev. #2 (Evaporators).  The Evaporators EV-14 and EV-15 located in a boning room must be removed per management of changes (MOCs) MCF#006 and MCF#005 in August and September 2015 respectively.   c.   EDDYPACK-P&ID06, Rev. #1 (Evaporators).  The Evaporator EV-19 located in a chill room must be removed.    d.   EDDYPACK-P&ID07, Rev. #1 (Evaporators).  The Evaporator EV-30 located in a sausage holding cooler must be removed.    e.   EDDYPACK-P&ID09, Rev. #3 (Evaporators - 2006 Expansion).  Pipelines are undefined.    f.   EDDYPACK-P&ID14, Rev. # 1(Evaporators).  The Evaporator EV-89 located in a locker room must be removed per management of change MCF#004 in October 2015.

Issued

Jul 14, 2017

Abate by

Aug 30, 2017

Penalty

Initial $12,675 · Current $7,461 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP):       a.      On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not document that it complied with its chosen recognized and generally accepted good engineering practice such as ANSI/ASHRAE-15 (American Society of Heating Refrigeration Air-Conditioning and Engineering) (1994), Section 8.13.2, when it failed to set ammonia detectors in the engine room at a value not greater than TLV-TWA (Threshold limit value-time weighted average) exposing employees to toxic hazards of ammonia exposure.         b.       On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not document that it complied with its chosen recognized and generally accepted good engineering practice such as ANSI/ASHRAE-15 (American Society of Heating Refrigeration Air-Conditioning and Engineering) (1994), Section 9.7.8 and ANSI/IIAR-2 (International Institute Ammonia Refrigeration) (1992), Section A.4.1.1, when it failed to discharge anhydrous ammonia not less than 15ft above the adjoining ground level to atmosphere exposing employees to toxic hazards of ammonia exposure.       c.       On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not document that it complied with its chosen recognized and generally accepted good engineering practice such as ANSI/ASHRAE-15 (American Society of Heating Refrigeration Air-Conditioning and Engineering) (1994), Section 8.14(i)and ANSI/IIAR-2 (International Institute Ammonia Refrigeration) (1992), Section 4.4.11, when it failed to install a remote control shut off for mechanical equipment in the refrigerating machinery room (such as but not limited to emergency stop buttons) immediately outside the engine room entrance doors exposing employees to toxic hazards of ammonia exposure.        d.        On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not document that it complied with its chosen recognized and generally accepted good engineering practice such as ANSI/ASHRAE-15 (American Society of Heating Refrigeration Air-Conditioning and Engineering) (1994), Section 8.14(i), when it failed to install a control switch for ventilation fans immediately outside the engine room entrance doors exposing employees to toxic hazards of ammonia exposure.        e.        On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not document that it complied with its chosen recognized and generally accepted good engineering practice such as ANSI/ASHRAE-15 (American Society of Heating Refrigeration Air-Conditioning and Engineering) (1994), Section 8.13.2, and ANSI/IIAR-2 (International Institute Ammonia Refrigeration) (1992), Section 4.4.1, when it failed to have the ceiling tightly sealed to the walls of the engine room exposing employees to toxic hazards of ammonia exposure.

Issued

Jul 14, 2017

Abate by

Aug 2, 2017

Penalty

Initial $9,054 · Current $5,251 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not ensure that PHA recommendations were resolved in a timely manner:  On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not resolve PHA recommendations in a timely manner such as but not limited to:      a. 2007 PHA, item # 14: Label equipment controls, valves and piping to provide clear operator recognition in accordance with standard industry practice- King valve did not have a sign.      b. 2012 PHA, item # 33: Install sail switch or other alarm to indicate continuous ventilation stoppage.

Issued

Jul 14, 2017

Abate by

Aug 2, 2017

Penalty

Initial $12,675 · Current $7,461 Reduced

General-duty citation text

29 CFR 1910.119(f)(3): The operating procedures were not reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer did not annually certify that operating procedures were current and accurate:     On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not annually certify operating procedures to ensure that they are current and accurate. The following are examples of inaccuracies noted:       a. EP-SOP-01-Overall System Operation, Revision #0 (02/21/12).  The procedure was not annually certified in 2016 and was found to be inaccurate, in that, the ammonia concentrations in parts per million (ppm) were listed as 50ppm, 75 ppm and 150 ppm for the auto-dialer to notify refrigeration managers and to shutdown a refrigeration system.  This information was incorrect per Process Safety Information Administrative Procedure.       b. EP-SOP-07-Evaporation Operation, Revision #0 (02/21/12).  The procedure was not annually certified in in 2016 and was found to be inaccurate. The procedure should exclude evaporators EV-14, EV-15, EV-19, EV-30 and EV-89 because these evaporators were removed.

Issued

Jul 14, 2017

Abate by

Aug 30, 2017

Penalty

Initial $12,675 · Current $7,461 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:      On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not perform tests on process equipment for the ammonia refrigeration systems such as but not limited to the following.    a.     Oil Pressure Differential Cut Out for the compressor #11  b.     High and Low Pressure Cut Out for the compressor #9  c.     High temperature Cutout for the compressor #8  d.     High and Low Level Controls for the Low Temperature Re-circulator V-02  e.     Two Emergency Stop Buttons for the ammonia refrigeration system  f.      Liquid King Valve (V06-L06) for the high pressure receiver

Issued

Jul 14, 2017

Abate by

Aug 2, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment:   On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer failed to ensure written procedures of process equipment were established and implemented such as but not limited to.   a. Written procedure for testing Emergency stop buttons  b. Written procedure for testing Control levels for pressure vessels  c. Written procedure for testing Compressors cutouts

Issued

Jul 14, 2017

Abate by

Aug 2, 2017

Penalty

Initial $5,432 · Current $3,150 Reduced

General-duty citation text

29 CFR 1910.119(i)(1):The employer did not perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.         On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not perform a pre-startup safety review for modifying and adding new equipment to the ammonia refrigeration system such as but not limited to.       a. Three ammonia vent lines/stacks were extended   b. Two new emergency stop buttons located outside the engine room door entrances   c. Two new visual and audible alarms located outside the engine room door entrances   d. One new visual and audible alarm located inside and on the South wall of the engine room   e. One new exhaust fan alarm inside the ammonia refrigeration office.

Issued

Jul 14, 2017

Abate by

Aug 2, 2017

Penalty

Initial $9,054 · Current $5,251 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:     On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not include procedures for handling small releases such as anhydrous ammonia and nitrogen in the emergency action plan.

Issued

Jul 14, 2017

Abate by

Aug 2, 2017

Penalty

Initial $5,432 · Current $3,150 Reduced

General-duty citation text

29 CFR 1910.119(o)(5): Employers did not retain the two (2) most recent compliance audit reports:      On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not retain the 2014 Process Safety Management (PSM) compliant audit reports

Issued

Jul 14, 2017

Abate by

Aug 2, 2017

Penalty

Initial $9,054 · Current $5,251 Reduced

General-duty citation text

29 CFR 1910.28(b)(1)(i)(A):  The employer did not ensure that each employee on a walking-working surface with an unprotected side or edge that is 4 feet (1.2 m) or more above a lower level is protected from falling by providing a guardrail system.    On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer failed to provide a guardrail system on a walking-working surface located next to the Thermosiphon V-21 exposing employees to falling hazards.

Issued

Jul 14, 2017

Abate by

Aug 2, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

1910.28(b)(3)(iv): Each employee was not protected from falling into a ladderway floor hole or ladderway platform hole by a guardrail system and toeboards erected on all exposed sides, except at the entrance to the hole, where a self-closing gate or an offset was not used.  a) On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, on the rooftop condenser platform, the employer allowed employees to conduct rounds and inspect the condenser near an unguarded ladderway floor opening.  b) On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, on the top Chiller platform, the employer allowed employees to conduct rounds and inspect the chiller near an unguarded ladderway floor opening.

Issued

Jul 14, 2017

Penalty

Initial $9,054 · Current $5,251 Reduced

General-duty citation text

29 CFR 1910.29(f)(7): The employer did not ensure handrails and the top rail of stair rail systems were capable of withstanding, without failure, a force of at least 200 pounds (890 N) applied in any downward or outward direction within 2 inches (5 cm) of any point along the top edge of the rail:    On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer allowed employees to use the unsecure combination of handrail and stair rail of the stair rail system in the engine room for accessing to an attic on daily basis exposing employees to falling hazard.

Issued

Jul 14, 2017

Abate by

Aug 2, 2017

Penalty

Initial $5,432 · Current $3,150 Reduced

General-duty citation text

29 CFR 1910.132(d)(1): The employer did not assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present.    On or about 01/17/2017, the employer did not assess noise hazards in the engine room area and allowed employees to work in the engine room area without requirement of hearing protection devices.

Issued

Jul 14, 2017

Abate by

Aug 2, 2017

Penalty

Initial $9,054 · Current $5,251 Reduced

General-duty citation text

29 CFR 1910.134(e)(1): The employer did not provide a medical evaluation to determine the employee's ability to use a respirator, before the employee was fit tested or required to use the respirator in the workplace:    On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer required employees to wear respirators during ammonia releases and when draining oil in the engine room and did not ensure that employees had received medical evaluations.     Note:  The employer may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator.

Issued

Jul 14, 2017

Abate by

Aug 2, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(f)(2): The employer did not ensure that an employee using a tight-fitting facepiece respirator was fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) was used, and at least annually thereafter      On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer required employees to wear respirators during ammonia releases and when draining oil in the engine room and did not ensure that employees had received fit tests.

Issued

Jul 14, 2017

Abate by

Aug 2, 2017

Penalty

Initial $5,432 · Current $3,150 Reduced

General-duty citation text

29 CFR 1910.134(h)(1): The employer did not provide each respirator user with a respirator that is clean, sanitary, and in good working order. The employer did not ensure that respirators are cleaned and disinfected using the procedures in Appendix B-2 of this section, or procedures recommended by the respirator manufacturer, provided that such procedures are of equivalent effectiveness.         On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not ensure that a Self-Contained Breathing Apparatus (SCBA) was clean, sanitary and in good working condition.

Issued

Jul 14, 2017

Abate by

Aug 2, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(h)(3)(iii):   Self-contained breathing apparatus was not inspected monthly.     On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not ensure that two Self-Contained Breathing Apparatus (SCBA) were inspected monthly.

Issued

Jul 14, 2017

Abate by

Aug 2, 2017

Penalty

Initial $5,432 · Current $3,150 Reduced

General-duty citation text

29 CFR 1910.151(c): Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.    Instance a: On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not ensure that the emergency eyewash and body shower station located outside the engine room was activated in accordance with ANSI/ISEA Z358.1 (American National Standard for Emergency Eyewash and Shower Equipment)      Instance b: On or about 01/17/2017, at the Eddy Packing Inc. facility located in Yoakum Texas, the employer did not ensure that the emergency eyewash and body shower station located inside the engine room was activated in accordance with ANSI/ISEA Z358.1 (American National Standard for Emergency Eyewash and Shower Equipment)