OSHA Inspection: K2D INC

Issued

Nov 29, 2018

Abate by

Apr 15, 2019

Penalty

Initial $5,654 · Current $4,000 Reduced

General-duty citation text

OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to ammonia hazards:      (a)  K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On and preceding 7/16/18, the employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to ammonia hazards.  The facility utilized an ammonia refrigeration system, approximately fifty years in age.  The ammonia receiver was fitted with two pressure relief valves.  The valves had not been replaced or inspected in at least ten years.  This condition exposed employees to an ammonia hazard.    (b)  K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On and preceding 7/16/18, the employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to ammonia hazards.  The facility utilized an ammonia refrigeration system, approximately fifty years in age.  The ammonia receiver was fitted with two pressure relief valves.  The exhaust piping for the receiver pressure relief valves was located behind the facility, in an alley adjacent to the maintenance shop.  The discharge point was located atop the maintenance shop roof, adjacent to two cooling towers.  The discharge point for the exhaust was at or below the roofline of the contiguous structure across the alley.  This condition exposed employees to an ammonia hazard.    (c)  K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On and preceding 7/16/18, the employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to ammonia hazards.  The facility utilized an ammonia refrigeration system, approximately fifty years in age.  The employer reported that approximately 1,000 pounds of ammonia had been lost from the refrigeration system over a two to three year period.  The employer had not performed mandated inspections and maintenance of process equipment, including but not limited to pressure vessels, piping, valves, compressors, and pumps, per International Institute of Ammonia Refrigeration IIAR 2 "Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems".  This condition exposed employees to an ammonia hazard.    (d)  K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On and preceding 7/16/18, the employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to ammonia hazards.  The facility utilized an ammonia refrigeration system, approximately fifty years in age.  The employer utilized a Cool Air Inc model LBW-50 ammonia leak detector with two sensors, one located in the compressor room and one in the production area.  The alarm panel was located in the compressor room.  No instrumentation was present that reported ammonia concentration levels.  The sole audible alarm signal was located in the maintenance shop, which was not manned at all times.  The employer did not ensure that the ammonia detection system, when finding ammonia levels at hazardous concentrations, was able to notify employees through audible and visual signals and ensure a prompt evacuation.  This condition exposed employees to an ammonia hazard.

Issued

Nov 29, 2018

Abate by

Jan 3, 2019

Penalty

Initial $4,240 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.30(b)(1): The employer did not train each employee on or before May 17, 2017, in the proper care, inspection, storage, and use of equipment covered by this subpart before an employee used the equipment:      (a) K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On or about 6/25/18, the employer did not train each employee in the proper care, inspection, storage, and use of equipment covered by this subpart before an employee used the equipment.  Employees removed an ammonia refrigeration unit.  Employees used a saw to cut piping.  Employees performed this task using a scissor lift.  Employees were not provided training on the scissor lift prior to their use of it.  This condition exposed employees to a fall hazard.

Issued

Nov 29, 2018

Abate by

Apr 15, 2019

Penalty

Initial $5,654 · Current $4,000 Reduced

General-duty citation text

29 CFR 1910.120(q)(6)(iii):  Employees who participated as hazardous materials technicians, or were expected to participate as hazardous materials technicians, had not received at least 24 hours of training equal to the first responder operations level, and had not been certified as having such training, and, in addition, did not demonstrate  competency in paragraphs (q)(6)(iii)(A)-(I) of this section:    (a)  K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On and preceding 7/16/18, the employer did not ensure that employees who participated as hazardous materials technicians, or were expected to participate as hazardous materials technicians, had received at least 24 hours of training equal to the first responder operations level, and had been certified as having such training, and, in addition, demonstrated competency in paragraphs (q)(6)(iii)(A)-(I) of this section.   Employees performed maintenance upon an ammonia refrigeration system.  Two maintenance employees were expected to investigate and respond to ammonia leaks or alarms.  Actions were to include stopping the leak, and/or reporting a leak to safety management for evacuation of the facility.  The employees had not been provided HazWoper training.  This condition exposed employees to an ammonia hazard.

Issued

Nov 29, 2018

Abate by

Apr 15, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.120(q)(10):  Chemical protective clothing and equipment to be used by organized and designated HAZMAT team members, or to be used by hazardous materials specialists, did not meet the requirements of 29 CFR 1910.120(g)(3) through (5):    (a)  K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On and preceding 7/16/18, the employer did not ensure that chemical protective clothing and equipment to be used by organized and designated HAZMAT team members, or to be used by hazardous materials specialists, met the requirements of 29 CFR 1910.120(g)(3) through (5).  Employees performed maintenance upon an ammonia refrigeration system.  Two maintenance employees were expected to investigate and respond to ammonia leaks or alarms.  Actions were to include stopping the leak, and/or reporting a leak to safety management for evacuation of the facility.  The employees were not provided appropriate respiratory protection or functional portable ammonia detection equipment.  This condition exposed employees to an ammonia hazard.

Issued

Nov 29, 2018

Abate by

Apr 15, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(c)(1): The employer did not establish and maintain a written respiratory protection program, as specified in subparagraphs (c)(1)(i) through (ix), in that employees were required to wear respirators during work operations:    (a)  K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On and preceding 7/16/18, the employer did not establish and maintain a written respiratory protection program, as specified in subparagraphs (c)(1)(i) through (ix), in that employees were required to wear respirators during work operations.  Employees performed maintenance upon an ammonia refrigeration system.  Employees were required to wear MSA tight fitting air purifying full face respirators with ammonia cartridges when responding to a leak of ammonia.  The employer did not have a written respiratory protection program.  This condition exposed employees to a respiratory hazard.

Issued

Nov 29, 2018

Abate by

Apr 15, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(d)(1)(iii): The employer did not identify and evaluate the respiratory hazard in the workplace:      (a)  K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On and preceding 7/16/18, the employer did not identify and evaluate the respiratory hazard in the workplace.  Employees performed maintenance upon an ammonia refrigeration system.  Employees drained the oil pot.  Employees may be exposed to ammonia when draining the oil pot.  Employees did not use or have respiratory protection when performing this task.  Employees were not provided monitors or other real-time instrumentation to measure the concentration of ammonia present while performing oil pot draining.  This condition exposed employees to a respiratory hazard.    (b)  K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On or about 6/25/18, the employer did not identify and evaluate the respiratory hazard in the workplace.  Employees performed maintenance upon an ammonia refrigeration system.  Employees removed an ammonia refrigeration unit.  Employees drained oil from the piping prior to the line breaks and used compressed air to blow out residual oil containing ammonia.  Employees were exposed to ammonia during this process.  Employees were not provided monitors or other real-time instrumentation to measure the concentration of ammonia present while performing this task.  This condition exposed employees to a respiratory hazard.    (c)  K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On or about 6/6/18, the employer did not identify and evaluate the respiratory hazard in the workplace.  Employees used a hose to spray water upon the floor of the chemical room to clean it prior to its demolition.  The floor contained residues of concentrated Ecolab Inc Sanova SAS Activator (containing sodium hydrogen sulfate) and Ecolab Inc Antimicrobial Food Additive Base (containing sodium chlorite).  The reaction of the two chemicals may release chlorine.  The employer did not identify and evaluate employee potential exposure to chlorine when cleaning the chemical room floor.  This condition exposed employees to a respiratory hazard.

Issued

Nov 29, 2018

Abate by

Apr 15, 2019

Penalty

Initial $0 · Current $0

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:      (a)  K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On and preceding 7/16/18, 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.  Employees performed maintenance upon an ammonia refrigeration system.  Employees were required to wear MSA tight fitting air purifying full face respirators with ammonia cartridges when responding to a leak of ammonia.  The employer did not provide a medical evaluation to each employee required to wear a respirator when responding to an ammonia leak.  This condition exposed employees to a respiratory hazard.

Issued

Nov 29, 2018

Abate by

Apr 15, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(f)(2): The employer did not ensure that employees using a tight-fitting facepiece respirator were fit tested prior to initial use of the respirator, whenever a different respirator facepiece was used, and at least annually thereafter:      (a)  K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On and preceding 7/16/18, the employer did not ensure that employees using a tight-fitting facepiece respirator were fit tested prior to initial use of the respirator, whenever a different respirator facepiece was used, and at least annually thereafter.  Employees performed maintenance upon an ammonia refrigeration system.  Employees were required to wear MSA tight fitting air purifying full face respirators with ammonia cartridges when responding to a leak of ammonia.  The employer had not provided a fit test.  This condition exposed employees to a respiratory hazard.

Issued

Nov 29, 2018

Abate by

Apr 15, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(k)(1): The employer did not provide effective, comprehensive, understandable, annual respirator training to employees who are required to use respirators:    (a) K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On and preceding 7/16/18, the employer did not provide effective, comprehensive, understandable, annual respirator training to employees who are required to use respirators.  Employees performed maintenance upon an ammonia refrigeration system.  Employees were required to wear MSA tight fitting air purifying full face respirators with ammonia cartridges when responding to a leak of ammonia.  The employer had not provided annual comprehensive respirator training to those employees required to wear respiratory protection when responding to an ammonia leak.  This condition exposed employees to a respiratory hazard.

Issued

Nov 29, 2018

Abate by

Jan 3, 2019

Penalty

Initial $5,654 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.133(a)(1): The employer did not ensure that each affected employee use appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation:     (a)  K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On or about 6/18/18, the employer did not ensure that each affected employee use appropriate eye or face protection when exposed to eye or face hazards from liquid chemicals or acids or caustic liquids.  Employees used a hose to spray water upon the floor of the chemical room to clean it prior to its demolition.  The floor contained residues of concentrated Ecolab Inc Sanova SAS Activator (containing sodium hydrogen sulfate) and Ecolab Inc Antimicrobial Food Additive Base (containing sodium chlorite).  Concentrated Sanova SAS Activator is acidic, while concentrated Food Additive Base is caustic.  The employer did not ensure that the employees wore appropriate eye protection from the acidic and caustic liquids mist or splash.  This condition exposed employees to a chemical hazard.

Issued

Nov 29, 2018

Abate by

Apr 15, 2019

Penalty

Initial $4,240 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.147(c)(2)(ii): The employer's energy control program under paragraph (c)(1) of this section did not utilize lockout, where the energy isolating device was capable of being locked out:      (a)  K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On or about 6/25/18, the employer's energy control program under paragraph (c)(1) of this section did not utilize lockout, where the energy isolating device was capable of being locked out.  Employees performed maintenance upon an ammonia refrigeration system.  Employees were directed to remove an ammonia refrigeration unit.  The refrigeration unit had multiple energy sources, including electrical and chemical.  Electrical power to the evaporator was shut off.  Employees closed six downstream and upstream piping valves to isolate the evaporator from the ammonia refrigeration system prior to cutting the piping.  Tags were placed on the gate valves.  The employer did not ensure that lockout devices were placed on the gate valves when it was feasible to do so.  This condition exposed employees to an ammonia hazard.

Issued

Nov 29, 2018

Abate by

Apr 15, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(c)(4)(i): Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:      (a)  K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On or about 6/25/18, procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section.  Employees performed maintenance upon an ammonia refrigeration system.  Employees were directed to remove an ammonia refrigeration unit.  The refrigeration unit had multiple energy sources, including electrical and chemical.  Electrical power to the evaporator was shut off.  Employees closed six downstream and upstream piping valves to isolate the evaporator from the ammonia refrigeration system prior to cutting the piping.  The employer did not develop and utilize procedures for this process.  This condition exposed employees to electrical and ammonia hazards.

Issued

Nov 29, 2018

Abate by

Apr 15, 2019

Penalty

Initial $4,240 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.1200(f)(6)(i): Except as provided in 29 CFR 1910.1200(f)(7) and 29 CFR 1910.1200(f)(8), the employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the information required by 29 CFR 1910.1200(f)(1)(i) through 29 CFR 1910.1200(f)(1)(v):    (a) K2D Inc, dba Colorado Premium Foods, at 2035 2nd Avenue, Greeley, CO: On and preceding 7/16/18, except as provided in 29 CFR 1910.1200(f)(7) and 29 CFR 1910.1200(f)(8), the employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the information required by 29 CFR 1910.1200(f)(1)(i) through 29 CFR 1910.1200(f)(1)(v).  The facility utilized an ammonia refrigeration system.  The system had approximately 8,000 pounds of ammonia within the process equipment and piping.  The ammonia receiver was located on the exterior of the facility adjacent to the maintenance shop and compressor room.  The receiver was marked "Ammonia".  The tank was not labeled, tagged, or marked identifying the hazards of ammonia.  This condition exposed employees to a chemical hazard.