OSHA Inspection: AL & JOHN, INC.

Issued

Jun 7, 2018

Abate by

Jul 26, 2018

Penalty

Initial $9,239 · Current $4,975 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): Information pertaining to the equipment in the process did not include piping and instrument diagrams (P&IDs):    a) The employer's piping and instrument diagram R04 did not accurately represent equipment that was existing and was part of the process in that a pressure/temperature gauge on TSR1-10 was omitted.       Violation occurred on or about 12/11/17.    b) The employer's piping and instrument diagram R06 did not accurately represent equipment in the process in that valves associated with pump 1 on R06 were associated with pump 2 in the plant.  Valves associated with pump 2 on R06 were associated with pump 1 in the plant.  Valves associated with pump 3 on R06 were associated with pump 4 in the plant.  Valves associated with pump 4 on R06 were associated with pump 3 in the plant.      Violation occurred on or about 12/11/17.    c) The employer's piping and instrument diagram R07 did not accurately represent equipment that was existing and was part of the process in that valves associated with pump 5 on R07 were associated with pump 6 in the plant.  Valves associated with pump 6 on R07 were associated with pump 5 in the plant.      Violation occurred on or about 12/11/17.

Issued

Jun 7, 2018

Penalty

Initial $9,239 · Current $4,975 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:      a) Engine room (35) - The employer failed to document compliance with RAGAGEP such as, but not limited to, IIAR Bulletin 109 (10/97) Section 4.10.10 when an emergency eyewash station and deluge body shower was not located just outside the machine room exit door, exposing employees to the hazard of chemical burns from contact with ammonia.      Violation occurred on or about 12/11/17.

Issued

Jun 7, 2018

Abate by

Jul 26, 2018

Penalty

Initial $9,239 · Current $4,975 Reduced

General-duty citation text

29 CFR 1910.119(f)(1): 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 and addressing at least steps for each operating phase, safe operating limits, safety and health considerations, and safety systems and their functions as outlined by this paragraph:    a)   Ammonia Delivery SOP      The employer failed to develop written operating procedures that provided clear instructions when the written operating procedure for ammonia delivery did not contain specific, clear instructions for actions/steps that needed to be taken inside the plant during delivery.      Violation occurred on or about 12/11/17.      b)     Equipment SOP for recirculators      The employer failed to develop written operating procedures that provided clear instructions when the written operating procedures for recirculators LTPR-1, MTPR-1 and HTPR-1 did not contain clear instructions on specific valves to be operated.     Violation occurred on or about 12/11/17.            c)    Equipment SOP for compressors      The employer failed to develop written operating procedures that provided clear instructions when the written operating procedures for compressors RB-1, RC-1, RC-2, RC-3, RC-4 and RC-5 did not contain clear instructions on specific valves to be operated.    Violation occurred on or about 12/11/17.      d)  Overall ammonia system operating procedures      The employer failed to develop written operating procedures that provided clear instructions for safely conducting operations during normal (planned) shutdown of the entire ammonia refrigeration system or emergency operations to include removal of ammonia released in the containment room.      Violation occurred on or about 12/11/17.

Issued

Jun 7, 2018

Abate by

Jul 26, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.119(f)(3): The employer did not annually certify that operating procedures were current and accurate:      a)  Refrigerant pumps      The employer failed to ensure that operating procedures were current and accurate when the operating procedures for refrigerant pumps RP-1, RP-2, RP-3, RP-4, RP-5 and RP-6 were written 6/10/15 and not reviewed and recertified until 1/14/18.        Violation occurred on or about 12/11/17.      b) Recirculators      The employer failed to ensure that operating procedures were current and accurate when the operating procedures for recirculators LTPR-1, MTPR-1 and HTPR-1 were written 3/9/16 and not reviewed and recertified until 1/14/18.      Violation occurred on or about 12/11/17.        c)  Ammonia deliveries      The employer failed to ensure that operating procedures were current and accurate when the last certification of the operating procedure for ammonia delivery was 2/16/12.      Violation occurred on or about 12/11/17.    d) Emergency Stop System (E--Stop) Description and Operation    The employer failed to ensure that operating procedures were current and accurate when the operating procedure for emergency shutdown of the entire ammonia refrigeration system was written in 2/16/12 and not reviewed and recertified until 2/18/18.    Violation occurred on or about 12/11/17.

Issued

Jun 7, 2018

Abate by

Jul 26, 2018

Penalty

Initial $9,239 · Current $4,975 Reduced

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:      b) Compressor room 35 - The employer failed to properly document its mechanical integrity procedure when it failed to perform electrical components of Class A inspections on compressors RB-1, RC-1, RC-2, RC-4 and RC-5 in 2017.      Violation occurred on or about 12/11/17.      c) Compressor room 35  The employer failed to properly document its mechanical integrity procedure when it failed to perform electrical components of Class B inspections on compressors RB-1 and RC-5 in 2017.      Violation occurred on or about 12/11/17.

Issued

Jun 7, 2018

Abate by

Jul 26, 2018

Penalty

Initial $9,239 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment was not consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience:    a) Compressor room 35  The employer failed to properly document that the frequency of inspections and tests conducted on compressors RB-1, RC-1, RC-2, RC-4 and RC-5 was consistent with manufacturer recommendations when Class A inspections were not completed in 2017.      Violation occurred on or about 12/11/17.      b) Compressor room 35  The employer failed to properly document that the frequency of inspections and tests conducted on compressors RB-1 and RC-5 was consistent with manufacturer recommendations when annual Class B inspections were not completed in 2017.      Violation occurred on or about 12/11/17.

Issued

Jun 7, 2018

Penalty

Initial $9,239 · Current $4,975 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(iv): Documentation of each inspection and test that had been performed on process equipment 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) Establishment    The employer failed to document each inspection and test performed on process equipment when records of visual inspection of piping under work orders issued 1/12/18 and 1/18/18 did not include the specific piping segments inspected, the results of the inspection or the date completed.      Violation occurred on or about 1/12/18.

Issued

May 10, 2018

Penalty

Initial $9,239 · Current $7,460 Reduced

General-duty citation text

29 CFR 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 must be used:    a) Workplace, Boiler Room, 147 Clinton Rd., West Caldwell, NJ    Employees accessed a 2nd floor mezzanine area approximately 14 feet above the boiler room floor, using a portable extension ladder,  through a hatchway door that was kept open.  The landing around this access hatchway did not have any means of fall protection such as guardrails, exposing the employees to a fall hazard of approximately 14 feet.     Violation occurred on or about 2/8/18.