OSHA Inspection: BONDUELLE USA, INC.

Issued

May 9, 2018

Abate by

Aug 31, 2018

Penalty

Initial $9,239 · Current $9,239

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 was protected from falling by a standard guardrail system.    a) On or about 11/16/17 on the mezzanine: employees who inspect and service equipment on the mezzanine located outside of Engine room #2 were exposed to a fall hazard of approximately 15 feet when a section of the walkway between condensers #1 & #3 was missing a mid rail and did not have a continuous top or bottom rail.      ABATEMENT CERTIFICATION REQUIRED

Issued

May 9, 2018

Abate by

Aug 31, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.28(b)(3)(i): The employer did not ensure each employee is protected from falling through any hole (including skylights) that is 4 feet (1.2 m) or more above a lower level by one or more of the following: covers, guardrail systems, travel restraint systems, or personal fall arrest systems, as required by sub-items A through D of this section.    a) On or about 11/16/17 on the outdoor condenser mezzanine adjacent to Engine Room #2 ; employees were exposed to a fall hazard of approximately 15 feet while walking and or working on the walkway in proximity to corner of #3 condensers and the face of # 1 when there was an opening of approximately 10 inches wide by 5 feet in length.      b) On or about 11/16/17 on the outdoor mezzanine adjacent to Engine Room #2 ; employees were exposed to a fall hazard of approximately 15 feet while walking and or working on the walkway west of condenser # 1 when there was an opening approximately 10 inches wide by five feet in length.      ABATEMENT CERTIFICATION REQUIRED

Issued

May 9, 2018

Abate by

Aug 31, 2018

Penalty

Initial $9,239 · Current $5,283 Reduced

General-duty citation text

29 CFR 1910.119(m)(6):  The report was not reviewed with all affected personnel whose job tasks were relevant to the incident findings including contract employees where applicable.

Issued

May 9, 2018

Abate by

Aug 31, 2018

Penalty

Initial $9,239 · Current $9,239

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)  On or about 11/16/2017, System #2; the employer failed to document that the sliding door on the east wall of engine room #2 complied with the employer's chosen RAGAGEP such as, but not limited to, Section 8.12(b) of ASHRAE 15-2010 and/or Section 10.14(b) of ASHRAE 15-1989, when there was an approximately 4-inch gap between the bottom of the door and the floor, exposing employees to the hazards of ammonia in the event of a release in engine room #2.      b) On or about 11/16/2017, System #2; the employer failed to document that the sliding door on the east wall of engine room #2 complied with the employer's chosen RAGAGEP such as, but not limited to, Section 8.12(b) of ASHRAE 15-2010 and/or Section 10.14(b) of ASHRAE 15-1989, when it was observed to be open and was not self-closing, exposing employees to the hazards of ammonia in the event of a release in engine room #2.      c) On or about 11/16/2017, System #2; the employer failed to document that two wall penetrations for 5 ammonia containing pipes in engine room #2 complied with the employer's chosen RAGAGEP such as, but not limited to, Section 8.12(b) of ASHRAE 15-2010 and/or Section 10.14(f) of ASHRAE 15-1989, when the wall openings were clearly visible and not sealed, exposing employees to the hazards of ammonia in the event of a release in engine room #2.      d) On or about 11/16/2017, in Engine Room #1; the employer failed to document that the High Stage Oil Separator 0003 complied with the employer's chosen RAGAGEP such as, but not limited to, Section 4.2 of IIAR Bulletin 114-1991 ?Guidelines for: Identification of Ammonia Refrigeration Piping System Components?, when it was not identified properly with markers including the name of the equipment and pressure level designation, exposing employees to the hazards of ammonia in the event of a release due to misidentification of equipment.      e) On or about 11/16/2017, in Engine Room #1; the employer failed to document that the High Stage Oil Separator 0004 complied with the employer's chosen RAGAGEP such as, but not limited to, Section 4.2 of IIAR Bulletin 114-1991 ?Guidelines for: Identification of Ammonia Refrigeration Piping System Components?, when it was not identified properly with markers including the name of the equipment and pressure level designation, exposing employees to the hazards of ammonia in the event of a release due to misidentification of equipment.      f) On or about 11/16/2017, in Engine Room #1; the employer failed to document that the Intercooler 0001 complied with the employer's chosen RAGAGEP such as, but not limited to, Section 4.2 of IIAR Bulletin 114-1991 ?Guidelines for: Identification of Ammonia Refrigeration Piping System Components?, when it was not identified properly with markers including the name of the equipment and pressure level designation, exposing employees to the hazards of ammonia in the event of a release due to misidentification of equipment.      g) On or about 11/16/2017, in Engine Room #1; the employer failed to document that the Intercooler 0002 complied with the employer's chosen RAGAGEP such as, but not limited to, Section 4.2 of IIAR Bulletin 114-1991 ?Guidelines for: Identification of Ammonia Refrigeration Piping System Components?, when it was not identified properly with markers including the name of the equipment and pressure level designation, exposing employees to the hazards of ammonia in the event of a release due to misidentification of equipment.      h) On or about 11/16/2017, in Engine Room #2; the employer failed to document that the High Stage Oil Separator 0005 complied with the employer's chosen RAGAGEP such as, but not limited to, Section 4.2 of IIAR Bulletin 114-1991 ?Guidelines for: Identification of Ammonia Refrigeration Piping System Components?, when it was not identified properly with markers including the name of the equipment and pressure level designation, exposing employees to the hazards of ammonia in the event of a release due to misidentification of equipment.      i) On or about 11/16/2017, in Engine Room #2; the employer failed to document that the High Stage Oil Separator 0006 complied with the employer's chosen RAGAGEP such as, but not limited to, Section 4.2 of IIAR Bulletin 114-1991 ?Guidelines for: Identification of Ammonia Refrigeration Piping System Components?, when it was not identified properly with markers including the name of the equipment and pressure level designation, exposing employees to the hazards of ammonia in the event of a release due to misidentification of equipment.      j) On or about 11/16/2017, in Engine Room #2; the employer failed to document that the Intercooler 0004 complied with the employer's chosen RAGAGEP such as, but not limited to, Section 4.2 of IIAR Bulletin 114-1991 ?Guidelines for: Identification of Ammonia Refrigeration Piping System Components?, when it was not identified properly with markers including the name of the equipment and pressure level designation, exposing employees to the hazards of ammonia in the event of a release due to misidentification of equipment.      k) On or about 11/16/2017, in Engine Room #2; the employer failed to document that the ammonia piping by Intercooler 0003 near the oil pot tag 8005 complied with the employer's chosen RAGAGEP such as, but not limited to, Section 4.1 of IIAR Bulletin 114-1991 ?Guidelines for: Identification of Ammonia Refrigeration Piping System Components?, when it was not identified properly with markers of the physical state, the relative pressure level, and the direction of the flow of ammonia, exposing employees to the hazards of ammonia in the event of a release due to misidentification of piping.      l) On or about 11/16/2017, in Engine Room #2; the employer failed to document that the ammonia piping by Intercooler 0004 at tag 4520 & RV line tag 6524 complied with the employer's chosen RAGAGEP such as, but not limited to, Section 4.1 of IIAR Bulletin 114-1991 ?Guidelines for: Identification of Ammonia Refrigeration Piping System Components?, when it was not identified properly with markers of the physical state, the relative pressure level, and the direction of the flow of ammonia, exposing employees to the hazards of ammonia in the event of a release due to misidentification of piping.        ABATEMENT CERTIFICATION REQUIRED

Issued

May 9, 2018

Penalty

Initial $9,239 · Current $7,000 Reduced

General-duty citation text

29 CFR 1910.119(f)(1)(iii)(B): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information which addressed precautions necessary to prevent exposure, including personal protective equipment.    a) On or about 11/16/17 in the Ammonia Refrigeration Engine Rooms; employees were exposed to contact with ammonia vapors and liquid when the operating procedures for oil draining, such as but not limited to, Oil Pot Intercooler 2 ( OP/IC 2 ) SOP, referred the operator to the anhydrous ammonia SDS sheet rather than describing the required personal protective equipment for this activity in the SOP.     NO ABATEMENT CERTIFICATION REQURIED

Issued

May 9, 2018

Abate by

Dec 1, 2018

Penalty

Initial $9,239 · Current $9,239

General-duty citation text

29 CFR 1910.119(j)(2): The employer did not establish written procedures to maintain the on-going integrity of process equipment;     a) On or about 11/16/17 throughout the ammonia refrigeration system; employees were exposed to a catastrophic release of ammonia vapors and liquid when the employer did not establish written procedures for the inspection of equipment insulation, piping, vessels and other ammonia containing equipment.      b) On or about 11/16/17 throughout the ammonia refrigeration system; employees were exposed to a catastrophic release ammonia vapors and liquid during the inspection and maintenance of valves used in ammonia service when the employer did not establish written procedures for the inspection and maintenance of valves and other similar ammonia containing equipment.      c) On or about 11/16/17 in Engine Room #3; employees were exposed to a catastrophic release ammonia vapors and liquid when they used the ammonia rated hose labeled "2001 and use no later than 2007" for making transfers of ammonia and the employer did not establish written procedures for the maintenance of ammonia rated hoses.     d) On or about 11/16/17 throughout the ammonia refrigeration system; employees were exposed to a catastrophic release ammonia vapors and liquid during the inspection and maintenance of safety relief valves when the employer did not establish written procedures for the inspection and replacement of these devices.        ABATEMENT CERTIFICATION REQUIRED

Issued

May 9, 2018

Abate by

Aug 31, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information on paragraph (d) of this section) before use;       a) On or about 11/16/17 in Engine Room #3; employees were exposed to a catastrophic release ammonia vapors and liquid when they used the ammonia rated hose labeled "2001 and use no later than 2007" for making transfers of ammonia and the employer did not establish written procedures for the maintenance of ammonia rated hoses.     ABATEMENT CERTIFICATION REQUIRED

Issued

May 9, 2018

Abate by

Jun 11, 2018

Penalty

Initial $7,391 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.119(h)(2)(v): The employer did not periodically evaluate the performance of contract employers to ensure they are fulfilling their obligations as specified in 29 CFR 1910.119(h)(3).    a) On or about 11/07/17 throughout the facility; employees were exposed to contact with ammonia vapors and liquids when the employer's last evaluation of contract employees working on the ammonia refrigeration system last occurred in 2015.     ABATEMENT CERTIFICATION REQUIRED