OSHA Inspection: WORLD CLASS DISTRIBUTION INC.

Issued

Aug 21, 2018

Abate by

Oct 9, 2018

Penalty

Initial $5,543 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employers compilation of written process safety information pertaining to the equipment in the process did not include accurate Piping and Instrument diagrams (P&ID's);.     (a) The employer did not ensure that the Piping and Instrumentation diagrams (P&ID's) accurately depicted the ammonia detector shut-down levels. The P&ID (sheet 2.4) indicated that the level at which process equipment in the machinery room would be shut-down; was 3,000 ppm; when in fact the detectors were programmed to shut-down at 500 ppm.

Issued

Aug 21, 2018

Abate by

Oct 9, 2018

Penalty

Initial $5,543 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(F):The employers compilation of written process safety information pertaining to the equipment in the process did not include an accurate representation of the design codes and standards employed;     (a) The employers compilation of written process safety information pertaining to the equipment in the process did not include an accurate representation of the design codes and standards employed. Process Safety Information provided by the employer did not include the specific consensus standard employed or the version or the date of the consensus standard.

Issued

Aug 21, 2018

Abate by

Oct 9, 2018

Penalty

Initial $12,934 · Current $0 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 (RAGAGAEP).    a. The employer did not document that it complied with its chosen recognized and generally accepted good engineering practice (RAGAGAEP) (ASHRAE 15, 2010, Section 8.11.2 and 8.12 b and IIAR 2008 addendum B Section13.1.10.1 ) when it failed to ensure that machinery room (north door) had a tight fitting door that opened outward.    b. The employer did not document that it complied with its chosen recognized and generally accepted good engineering practice (RAGAGAEP) (ASHRAE 15, 2010, (Section 9.7.8.2 b)  when it failed to ensure that where pressure relief devices discharge to a water tank, the water shall be prevented from freezing.                                                                                                                            c. The employer did not document that it complied with its chosen recognized and generally accepted good engineering practice (RAGAGAEP) (ASHRAE 15, 2010, (Section 8.11.2 and 8.12 f  and IIAR 2008 addendum B Sections 13.1.1.3 and 13.1.1.6 ) when it failed to seal openings in the walls in the engine room through which pipes pass.

Issued

Aug 21, 2018

Abate by

Oct 9, 2018

Penalty

Initial $9,239 · Current $0 Reduced

General-duty citation text

29 CFR 1910.119(f)(3): The employer did not review the operating procedures as often as necessary to assure that they reflect current operating practice. The employer did not certify annually that the operating procedures were current and accurate.    (a) The employer did not ensure that the operating procedures for the ammonia refrigeration system were certified annually. The operating procedures for the ammonia refrigeration system had not been certified since January 6, 2017; for equipment, such as but not limited to, the following:  1. High Pressure Receiver (HPR-1) 2. Compressors C1 to C5 3. High Temperature Recirculator (HTR-1); RP-1 and RP-2 4. Low Temperature Recirculator  (LTR-1);  RP-3 and RP-4 5. C1-C5 Coalescer 6. Oil Pot for HTR-1 and Oil Pot for LTR-1 7. AU-1 to AU-24 and AU-32 to AU-52 8. Condenser EC-1 9. Ventilation EF-1 and EF-2 10. Surge drum MAU-1 11. Auto Purger AP-1 12. Makeup Air Unit MAU-1    (b) The employer did not ensure that the following operating procedures were current and accurate in that there is a reference to the required use and availability of self-contained breathing apparatus which are not present on the site:    1.   C-3 to C-5 section Required PPE 2.   AU-51 Freezer Evaporator section 1A.4; 3.   Initial Start-up section 1.4    (c) The employer did not ensure that the following operating procedures were current and accurate in that there is a reference to  Lock-out Tagout Procedures as a requirement. Lock-out Tagout Procedures are not implemented for the Pumpout/Draining Oil operation.

Issued

Aug 21, 2018

Abate by

Oct 9, 2018

Penalty

Initial $9,239 · Current $0 Reduced

General-duty citation text

1910.119(g)(2) The employer did not provide refresher training at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process:    (a)  The employer did not provide an employee with  refresher training annually, as is provided in their process safety management program, or at least every three years in accordance with 1910.119(g)(2).      The maintenance manager/refrigeration operator who is involved in operating the process, providing oversight of the ammonia refrigeration system and is responsible for identifying problems in the operation of the ammonia refrigeration system, has not received refresher  training concerning operation of the system since 2014.

Issued

Aug 21, 2018

Abate by

Oct 9, 2018

Penalty

Initial $12,934 · Current $0 Reduced

General-duty citation text

1910.119(j)(4)(ii) The employers inspection and testing procedures did not follow recognized and generally accepted good engineering practices:    a. The employer did not test the mechanical ventilation system and associated alarm system in the machinery room on an annual basis in accordance with recognized and generally accepted good engineering practices, such as , but not limited to, IIAR Bulletin 2-2008 Addendum B, Section 13.3.12.2 which provides that on an annual basis a functional test be performed on the mechanical ventilation and alarm system to ensure that the system is performing as designed.

Issued

Aug 21, 2018

Abate by

Oct 9, 2018

Penalty

Initial $12,934 · Current $0 Reduced

General-duty citation text

1910.119(j)(4)(iii) The frequency of inspections and tests of process equipment is not consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.    (a) The employer did not perform testing of cutouts on process equipment (Compressors) in accordance with its mechanical integrity program, manufacturers recommendations, and consensus standards such as, but not limited to, IIAR Bulletin 110, 1993, Section 6.3.3 which provides that high pressure cutouts, low pressure cutouts, high temperature cutouts, and oil pressure differential cutouts be tested at least annually. The cutouts for compressors 1, 2, 3, 4, and 5 were not tested annually.   (b) The employer did not calibrate the facility ammonia detectors in accordance with their mechanical integrity program schedule, the manufacturers instructions; which require the detectors be calibrated every six months and consensus standards such as, but not limited to, IIAR 2 2008 Addendum B which requires that these devices be tested annually. World Class Distribution failed to calibrate the ammonia detectors every six months.

Issued

Aug 21, 2018

Abate by

Oct 9, 2018

Penalty

Initial $5,543 · Current $0 Reduced

General-duty citation text

1910.119(j)(4)(iv): The employer did not document for each inspection and test that has been performed on process equipment; the serial number or other identifier of the equipment on which the inspection or test was performed and a description of the inspection or test performed.    (a) The Ammonia Monitoring Sheet prepared by World Class Distribution did not document for each inspection conducted on process equipment; the serial number or other identifier of the equipment and a description of the inspection performed.

Issued

Aug 21, 2018

Abate by

Oct 9, 2018

Penalty

Initial $12,934 · Current $0 Reduced

General-duty citation text

1910.119(j)(5) The employer did not correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation:    (a) On or about March 15, 2018 the employer did not ensure that the ammonia exhaust ventilation system  for the machinery room was fully functional in that the louvres for the exhaust fan were not operational.  (b) On or about March 15, 2018 the employer had not installed a flow through sail switch to activate a supervised alarm notifying personnel that continuous flow through the louvres had stopped and that the exhaust system had failed.

Issued

Aug 21, 2018

Abate by

Oct 9, 2018

Penalty

Initial $9,239 · Current $0 Reduced

General-duty citation text

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.    (a) The employer did not implement the provisions of its emergency action plan in that no drills were documented and no evaluation of any drill has been performed using the Fire/Evacuation Drill Recap Form;  (b) The employer did not implement the provisions of its emergency action plan in that emergency evacuation training was not performed annually and did not conduct evacuation drills involving an ammonia release;  (c) The employers emergency action plan did not include procedures for handling small releases;  (d) The employer did not revise their emergency action plan to reflect that local personnel must be designated as the emergency coordinator.

Issued

Aug 21, 2018

Abate by

Oct 9, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

1910.119(o)(4) The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected:    (a) For the 2016 compliance audit, the employer did not promptly determine and document an appropriate response to a finding which stated the following:  Revise the emergency action plan to include facility personnel as Emergency Coordinator, alternates, etc. The Safety General Manager was listed but should be replaced with facility personnel.    The Safety General Manager, who is located in California, is still listed as the emergency response coordinator at the facility; hence this deficiency has not been corrected.

Issued

Aug 21, 2018

Abate by

Oct 9, 2018

Penalty

Initial $1,037 · Current $0 Reduced

General-duty citation text

1910.119(o)(1) The employers did not certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed:    (a) In their 2016 compliance audit the employer failed to certify that they have evaluated compliance with the provisions of 1910.119 to verify that the procedures and practices developed under the standard are adequate and are being followed.     The employer failed to certify the 2016 compliance audit.