OSHA Inspection: MORRAL COMPANIES, LLC

Issued

Oct 13, 2020

Abate by

May 3, 2021

Penalty

Initial $8,675 · Current $7,482 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(e)(1): The employer did not perform an initial process hazard analysis (hazard evaluation) on processes covered by 29 CFR 1910.119:  Morral Companies, LLC - Morral, Ohio - Anhydrous Ammonia Liquid Department:  On or about June 3, 2020, the employer did not have an initial PHA completed for the PSM-covered process which uses anhydrous ammonia to manufacture liquid fertilizer.  Failure to conduct an initial PHA to identify, evaluate and control the hazards of the process could lead to a catastrophic release of anhydrous ammonia and could expose process operators to inhalation and fire hazards.

Issued

Oct 13, 2020

Abate by

May 3, 2021

Penalty

Initial $8,675 · Current $0 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 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:  Morral Companies, LLC - Morral, Ohio - Anhydrous Ammonia Liquid Department:  On or about June 9, 2020, the employer did not implement a system to document responses and corrective action taken on compliance audit findings related to the use of anhydrous ammonia in fertilizer manufacturing in the Liquid Department.  Because the system was not developed, findings related to process safety management elements, such as but not limited to, mechanical integrity were not documented or corrected, including findings related to inspection, testing and maintenance of piping and piping components, such as valves.  Piping in anhydrous ammonia service between the anhydrous ammonia storage tanks and the Liquid Department was observed to have surface damage (e.g., chipped paint and external corrosion with rust present).  Failure to correct and address identified deficiencies in process safety management elements involving ammonia service can result in an unintended release, resulting in fire and inhalation hazards for process operators in the Liquid Department.

Issued

Oct 13, 2020

Abate by

May 3, 2021

Penalty

Initial $8,675 · Current $7,482 Reduced

Hazardous substances 0170

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:  Morral Companies, LLC - Morral, Ohio - Anhydrous Ammonia Liquid Department:  On or about June 9, 2020, the employer did not establish and implement written procedures for maintaining the on-going integrity of process equipment, such as but not limited to anhydrous ammonia piping and piping components, such as valves, which describe the extent and location of inspection activity, frequency of inspection and testing, and acceptance criteria from applicable piping inspection codes used to determine whether piping remains fit for service.  The employer uses anhydrous ammonia in the manufacture of liquid fertilizer products in the Liquid Department.  Piping in anhydrous ammonia service between the anhydrous ammonia storage tanks and the Liquid Department was observed to have chipped paint and corrosion.  Failure to maintain piping and piping components in ammonia service can result in an unintended release, resulting in fire and inhalation hazards.

Issued

Oct 13, 2020

Abate by

May 3, 2021

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:  Morral Companies, LLC - Morral, Ohio - Anhydrous Ammonia Liquid Department:  On or about June 9, 2020, the employer did not ensure that mechanical integrity inspections and testing was performed on process equipment such as but not limited to visually inspecting metal surfaces of piping and piping components, including valves, used to introduce anhydrous ammonia into the fertilizer mixing operations in the Liquid Department, to determine if piping remained fit for service and thickness testing (e.g. acceptable wall thickness).  Piping in anhydrous ammonia service between the anhydrous ammonia storage tanks and the Liquid Department was observed to have surface damage (e.g. chipped paint and external corrosion with some rust present).  Failure to inspect, test, and maintain piping and piping components in ammonia service can result in an unintended release, resulting in fire and inhalation hazards to process operators in the Liquid Department.

Issued

Oct 13, 2020

Abate by

Jan 4, 2021

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(g)(3):  The employer did not ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The employer did not prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.  Morral Companies, LLC - Morral, Ohio - Anhydrous Ammonia Liquid Department:  On or about June 9, 2020, the employer did not ensure that training for operators in the Liquid Department was documented with regards to the dates of training and means used to verify that employees understood the training, which was previously provided by the manufacturer/installer of the process equipment.  Failure to have written training documentation showing the status of training for employees may result in employees not being trained on how to respond or prevent ammonia releases in the Liquid Department.