OSHA Inspection: SHAWS DISTRIBUTION CENTER #32711

Issued

2018-05-03 00:00:00

Abate by

2019-05-24 00:00:00

Penalty

Initial $10163.00 · Current $6000.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.28(b)(13)(ii): The employer did not ensure that employees working on low-slope roofs greater than six (6) feet, but less than fifteen (15) feet away from the edge were protected from falling by using a guardrail system, safety net system, travel restraint system, or personal fall arrest system; or where work performed is both infrequent and temporary, through the use of a designated area:      (a) Location - 100 Danton Drive, Methuen, MA:    On or about 4/18/2018, employees performing work on, and in the area of, the ammonia refrigeration system condenser were not protected from falling.

Issued

2018-05-03 00:00:00

Abate by

2019-05-24 00:00:00

Penalty

Initial $10163.00 · Current $4667.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): Written process safety information pertaining to the equipment in process did not include piping and instrument diagrams (P&IDs) accurately representing equipment that was existing and was part of the process:    (a) Location - 100 Danton Drive, Methuen, MA:    On or about 11/6/2017, the employers P&IDs for their ammonia refrigeration system contained the following discrepancies:  1. The pressure relief valves for the Horizontal Recirculator Package (HRP), High Pressure Receiver (HPTSR), and all four screw compressors vent to the same 4 relief line, and this is not depicted on the P&IDs.  2. The termination of the 4 relief line for the pressure relief valves associated with the HRP, HPTSR, and the screw compressors is not depicted on the P&IDs.  3. The P&IDs depicting Screw Compressors abbreviates Relief Line as RL, but on the P&ID legend it indicates that the abbreviation for Relief Line is RV.  4. Dual relief valves are depicted three different ways on the P&IDs and only one way is recognized on the P&ID legend.    5. The vertical risers connecting the Glycol Surge Drum and the Glycol Chiller are not depicted on the P&ID.  6. The drip pocket on the relief line for the pressure relief valves of the glycol surge drum are not depicted on the P&IDs.  7. Valve HRP-1 LX-1 is a normally closed valve and this is not indicated on the P&ID.

Issued

2018-05-03 00:00:00

Abate by

2019-05-24 00:00:00

Penalty

Initial $10163.00 · Current $6000.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(d)(3)(i)(D): Written process safety information pertaining to the equipment in a covered process did not include complete and accurate information demonstrating relief system design and design basis:    (a) Location - 100 Danton Drive, Methuen, MA (Engine Room):    On or about 11/6/2017, the inline hydrostatic pressure relief device installed in conjunction with the oil pot for the Horizontal Recirculator Package was not documented in the employer's relief system design and design basis;       (c) Location - 100 Danton Drive, Methuen, MA (Banana Room):      On or about 11/6/2017, the calculation performed to determine the minimum required discharge capacity of the pressure relief device for the Glycol Chiller did not account for the heat exchanger. ANSI/IIAR 2-1992, American National Standard for Equipment, Design, and Installation of Ammonia Mechanical Refrigeration Systems, the employers chosen design basis for the pressure relief system, Section 3.11.4.6 Required Capacity requires that when one pressure relief device is used to protect more than one pressure vessel, the required capacity shall be the sum of the capacities required for each pressure vessel.

Issued

2018-05-03 00:00:00

Abate by

2019-05-24 00:00:00

Penalty

Initial $10163.00 · Current $6000.00 Reduced

Hazardous substances 0170

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:    (a) Location - 100 Danton Drive, Methuen, MA:    On or about 11/6/2017, the employer did not document that its ammonia refrigeration equipment complied with recognized and generally accepted good engineering practice (RAGAGEP), such as IIAR 2, when an emergency eyewash was not located just outside the machine room exit door. IIAR 2  2014, Section 6.7.1, for example, and earlier editions of IIAR 2, requires each machinery room shall have access to a minimum of two eyewash/safety shower units, one located inside the machinery room and one located outside of the machinery room. This hazardous condition exposed employees to the hazard of contact with anhydrous ammonia.      (b) Location - 100 Danton Drive, Methuen, MA:      On or about 11/6/2017, the employer did not document that its ammonia refrigeration equipment complied with recognized and generally accepted good engineering practice (RAGAGEP), such as IIAR 2, when the termination of pressure relief discharge piping did not rise above the catwalk of the ammonia refrigeration system condenser it was installed next to. IIAR 2  2014, Section 15.5.1.2, for example, and earlier editions of IIAR 2, requires that the termination of pressure relief device discharge piping relieving to atmosphere shall be not less than 15 above grade. Additionally, where upper condenser catwalks are occupied solely during service and inspection the termination of the discharge piping is permitted to terminate not less than 7 1/4 above the platform surface. This condition exposed employees to the hazard of contact with anhydrous ammonia.    (c) Location - 100 Danton Drive, Methuen, MA:      On or about 11/6/2017, the employer did not document that its ammonia refrigeration equipment complied with recognized and accepted good engineering practices (RAGAGEP), such as NFPA 70, when rigid metal conduit installed in conjunction with the control valves for the evaporators was not adequately secured and supported. NFPA 70  2017, Article 344, for example, and earlier editions, requires that rigid metal conduit shall be securely fastened within 3 of each box, cabinet, conduit body, or other conduit termination and that conduit shall be supported at intervals not exceeding 10. This condition exposed employees to the hazard of contact with anhydrous ammonia.

Issued

2018-05-03 00:00:00

Abate by

2019-07-24 00:00:00

Penalty

Initial $12934.00 · Current $6000.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(d)(3)(iii): The employer did not determine and document that existing process equipment designed and constructed in accordance with codes, standards, or practices no longer in general use was designed, maintained, inspected, tested, and operating in a safe manner:       (a) Location - 100 Danton Drive, Methuen, MA:    On or about 11/6/2017, a determination concerning the safe design, maintenance, inspection, testing, and operation of the glycol chiller in the Banana Room has not been documented by the employer.

Issued

2018-05-03 00:00:00

Abate by

2019-05-24 00:00:00

Penalty

Initial $12934.00 · Current $4667.00 Reduced

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 - 100 Danton Drive, Methuen, MA:    On or about 11/6/2017, facility siting for the anhydrous ammonia refrigeration process, such as locations of ammonia refrigeration process equipment and associated piping in proximity to a banana ripening process utilizing a flammable liquid/gas subjected the equipment to fire/explosion hazards in the event of a fire/explosion originating in the banana ripening process area, has not been adequately addressed through process hazard analysis.      (b) Location  100 Danton Drive, Methuen, MA:      On or about 11/6/2017, facility siting for the anhydrous ammonia refrigeration process, such as the location of the glycol chiller in proximity to materials handling and storage activities subjected the glycol chiller to impact in the event of a loss of control, or incidentally due to inattention on the part of the operator, of a powered industrial truck, has not been adequately addressed through process hazard analysis.      (c) Location  100 Danton Drive, Methuen, MA:      On or about 11/6/2017, facility siting for the anhydrous ammonia refrigeration process, such as the location of evaporators in proximity to materials handling and storage activities subjected the evaporator to impact in the event of a loss of control, or incidentally due to inattention on the part of the operator, of a powered industrial truck, has not been adequately addressed through process hazard analysis.

Issued

2018-05-03 00:00:00

Abate by

2019-05-24 00:00:00

Penalty

Initial $10163.00 · Current $4666.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(g)(1)(i): Each employee involved in operating a covered process was not trained in an overview of the process and in the procedures as specified in paragraph (f) of 29 CFR 1910.119 with an emphasis on specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employees job tasks:    (a) Location - 100 Danton Drive, Methuen, MA:    On or about 11/6/2017, employees assigned the responsibility of compiling information for the Refrigeration Reading, Methuen, D.C. form have not been provided training in an overview of the ammonia refrigeration process and procedures specific to the ammonia refrigeration process with an emphasis on, amongst other topics, safe work practices applicable to their job tasks.

Issued

2018-05-03 00:00:00

Abate by

2019-05-24 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(g)(3): A written record containing the identity of the employee, the date of the training, and the means used to verify that the employee understood the training was not prepared to document training provided concerning the operation of a covered process:    (a) Location - 100 Danton Drive, Methuen, MA:    On or about 11/6/2017, documentation of training provided to employees assigned the responsibility of compiling information for the Refrigeration Reading, Methuen, D.C. form does not include information concerning the means used to verify that the employee understood the training.

Issued

2018-05-03 00:00:00

Abate by

2019-05-24 00:00:00

Penalty

Initial $10163.00 · Current $0.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(l)(5): a change covered by paragraph (l) of 1910.119 resulting in a change to an operating procedure or practice required by paragraph (f) of 1910.119 was made, and such procedures or practices were not updated accordingly:     (a) Location - 100 Danton Drive, Methuen, MA:    On or about 11/6/2017, system design limits (Suction Pressure) of the ammonia  refrigeration system compressors were changed and the System Design Limit section of the Refrigeration Reading, Methuen, D.C. form was not updated to reflect this change.

Issued

2018-05-03 00:00:00

Abate by

2019-05-24 00:00:00

Penalty

Initial $10163.00 · Current $6000.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(n): The employer did not establish and implement an emergency plan, including procedures for handling small releases, for the entire plant in accordance with the provisions of 29 CFR 1910.38:     (a) Location - 100 Danton Drive, Methuen, MA:    On or about 11/6/2017, the emergency action plan for the facility does not address small releases; did not include accurate evacuation procedures for loaders/unloaders and other employees, or what employees actually did, as required by 1910.38(c)(2); and did not include the name or job title of every employee who may be contacted by employees for information concerning the emergency action plan or an explanation of their duties under the plan, as required by 1910.38(c)(6).

Issued

2018-05-03 00:00:00

Abate by

2019-05-24 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 0170

General-duty citation text

29 CFR 1910.120(q)(1): The employer, who would evacuate employees from the danger area when an emergency occurred and would not permit any employees to assist in handling the emergency, did not provide an emergency action plan in accordance with 1910.38:    (a) Location - 100 Danton Drive, Methuen, MA:    On or about 11/6/2017, the emergency action plan for the facility does not include  procedures for emergency evacuations and 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. 29 CFR 1910.38(c)(2): The emergency action plan did not include procedures for emergency evacuation, including type of evacuation and exit route assignments:  (a) Location - 100 Danton Drive, Methuen, MA:  On or about 11/6/2017, procedures detailed in the emergency action plan did not accurately reflect actions on the part of loaders/unloaders, and other employees, that were actually expected of them, nor would employees actually perform those procedures as detailed in the event of an emergency.

Issued

2018-05-03 00:00:00

Abate by

2019-05-24 00:00:00

Penalty

Initial $10163.00 · Current $6000.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.178(m)(5)(i): Powered industrial trucks were left unattended and load engaging means were not fully lowered, controls were not neutralized, power was not shut off, and/or brakes were not set:    (a) Location - 100 Danton Drive, Methuen, MA:    On or about 4/18/2018, Class II and Class III powered industrial trucks were left unattended in the warehouse and their power was not shut off.