OSHA Inspection: MONOGRAM GOURMET FOODS, LLC

Issued

Oct 8, 2021

Abate by

Dec 15, 2021

Penalty

Initial $9,753 · Current $3,600 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process:  (a) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, the three way valve installed in conjunction with the pressure relief valves protecting the ammonia refrigeration system's high pressure receiver was depicted as a normally closed angle valve and an unidentified symbol on PID08 High Pressure Receiver V-1.

Issued

Oct 8, 2021

Abate by

Dec 15, 2021

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(d)(3)(i)(D): Process safety information pertaining to the equipment in the process did not include relief system design and design basis:  (a) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, documentation sufficient to show or describe the relief system design and design basis of the equipment in the ammonia refrigeration process has not been compiled and maintained as process safety information.

Issued

Oct 8, 2021

Abate by

Dec 15, 2021

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(d)(3)(i)(E): Process safety information pertaining to the equipment in the process did not include ventilation system design:  (a) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, documentation sufficient to show or describe the ventilation system design of the equipment in the ammonia refrigeration process has not been compiled and maintained as process safety information.

Issued

Oct 8, 2021

Abate by

Nov 15, 2021

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(d)(3)(i)(F): Process safety information pertaining to the equipment in the process did not include a list of design codes and standards employed:  (a) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, documentation sufficient to show or describe the codes and standards employed in the design of the equipment in the ammonia refrigeration process has not been compiled and maintained as process safety information.

Issued

Oct 8, 2021

Abate by

Jun 15, 2022

Penalty

Initial $9,753 · Current $4,800 Reduced

Hazardous substances 0170

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) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, the employer did not document that its ammonia refrigeration equipment complied with recognized and generally accepted good engineering practice (RAGAGEP), such as the International Mechanical Code (IMC), when they permanently installed an ammonia refrigeration system with a 22,000 lbs. system charge without an emergency pressure control system. IMC 2015, the employer's chosen RAGAGEP, Section 1105.9 requires that permanently installed refrigeration systems containing more than 6.6. pounds (3 kg) of flammable, toxic, or highly toxic refrigerant, or ammonia shall be provided with an emergency pressure control system in accordance with Section 606.10 of the International Fire Code. This hazardous condition exposed employees to the hazard of contact with anhydrous ammonia.  (b) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, the employer did not document that its ammonia refrigeration equipment complied with recognized and generally accepted good engineering practice (RAGAGEP), such as IIAR 2, when the maximum length of the discharge piping installed on Relief Line Designation C2 B-C exceeded the available pipe length as determined by Equation 15.5.1.1.1(1). IIAR 2 2014, the employer's chosen RAGAGEP, Section 15.5.1.1.1 requires that the design backpressure in the discharge piping at the outlet of pressure relief devices and fusible plugs, discharging through a single relief device shall be limited by the allowable equivalent length of piping determined by Equation 15.5.1.1.1(1) or 15.5.1.1.1(2). This hazardous condition exposed employees to the hazard of contact with anhydrous ammonia.  (c) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, the employer did not document that its ammonia refrigeration equipment complied with recognized and generally accepted good engineering practice (RAGAGEP), such as IIAR 2, when shut-off valve V204, which is used to drain oil from OP-1, was not capped, plugged, blanked, or locked while not in use.  IIAR 2 2014, the employer's chosen RAGAGEP, Section 13.3.6 requires that shut-off valves connecting ammonia-containing equipment or piping to atmosphere shall be capped, plugged, blanked, or locked closed during shipping, testing, operating, servicing, or standby conditions when they are not in use. This hazardous condition exposed employees to the hazard of contact with anhydrous ammonia.

Issued

Oct 8, 2021

Abate by

Nov 15, 2021

Penalty

Initial $9,753 · Current $3,600 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(f)(1)(iii)(D): Written operating procedures providing clear instruction for conducting operations in a covered process safely and consistently with process safety information addressing safety and health considerations such as quality control of raw materials have not been developed:  (a) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, written operating procedures providing clear instructions for ensuring quality control of raw materials, including anhydrous ammonia,  for the ammonia refrigeration system have not been developed.

Issued

Oct 8, 2021

Abate by

Dec 15, 2021

Penalty

Initial $9,753 · Current $4,800 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(g)(1)(i): Each employee involved in operating a covered process was not trained in an overview of the process and in the procedures as specified in paragraph (f) of 29 CFR 1910.119 with an emphasis on specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employees job tasks:  (a) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, employees assigned the responsibility of managing and supervising an employee who is responsible for operating the ammonia refrigeration system have not been provided training in an overview of the ammonia refrigeration process and procedures specific to the ammonia refrigeration process with an emphasis on, amongst other topics, safe work practices applicable to their job tasks.

Issued

Oct 8, 2021

Abate by

Nov 15, 2021

Penalty

Initial $9,753 · Current $4,800 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(j)(2): Written procedures to maintain the on-going integrity of process equipment have not been established:  (a) Location - 330 Ballardvale Street, Wilmington, MA:   On or about May 27, 2021, written procedures to maintain the on-going integrity of insulated and non-insulted piping of the ammonia refrigeration system have not been established.

Issued

Oct 8, 2021

Abate by

Nov 15, 2021

Penalty

Initial $9,753 · Current $3,600 Reduced

Hazardous substances 0170

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) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, documentation of a visual inspection conducted on ammonia refrigeration system piping on the roof and in the machinery room did not identify the date of the inspection and did not identify the name of the person who performed the inspection.

Issued

Oct 8, 2021

Abate by

Nov 15, 2021

Penalty

Initial $9,753 · Current $4,800 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(l)(1): Procedures to manage changes to process chemicals, technology, equipment and procedures, and changes to facilities that affect a covered process were not implemented:  (a) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, the facility's emergency action plan was changed to include a shelter in place procedure in response to releases of ammonia from the refrigeration system and management of change procedures established by the employer were not followed.  (b) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, the facility's emergency action plan was changed to prohibit the employees of the facility from assisting in responses to releases of ammonia from the refrigeration system and management of change procedures established by the employer were not followed.  (c) Location - 330 Ballardvale Street Wilmington, MA:  On or about May 27, 2021, the facility's Environmental, Health, and Safety Manager left the company and management of change procedures established by the employer were not followed.  (d) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, a compressor was taken offline with no intention of returning it to service and management of change procedures established by the employer were not followed.

Issued

Oct 8, 2021

Abate by

Mar 15, 2022

Penalty

Initial $9,753 · Current $4,800 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(n): The employer did not establish an emergency plan for the entire plant in accordance with the provisions of 29 CFR 1910.38:  (a) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, the facility's emergency action plan does not include adequate procedures for sheltering in place in accordance with the requirements of 29 CFR 1910.38(c)(2).  (b) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, the facility does not use a distinctive signal for each purpose identified in the emergency action plan in accordance with the requirements of 29 CFR 1910.38(d).  (c) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, the facility does not have established procedures for sounding emergency alarms in the workplace for each purpose identified in the emergency action plan in accordance with the requirements of 29 CFR 1910.165(b)(5).

Issued

Oct 8, 2021

Abate by

Mar 15, 2022

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR  1910.38(c)(2): The emergency action plan did not include procedures for emergency evacuation, including type of evacuation and exit route assignments:  (a) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, the facility's emergency action plan includes an option for sheltering in place in response to releases of ammonia from the refrigeration system, but does not indicate whom is responsible for determining whether to shelter in place or evacuate, what procedures may be necessary for turning off, sealing, or otherwise disabling HVAC equipment to prevent the infiltration of contaminated air from outside into the shelter, and does not indicate how the decision to shelter in place vice evacuate will be communicated to employees.

Issued

Oct 8, 2021

Abate by

Mar 15, 2022

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR  1910.38(d): The employer did not have and maintain an employee alarm system with a distinctive signal for each purpose that complied with the requirements in � 1910.165:  (a) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, the facility does not use a distinctive signal to alert employees as to whether they are to evacuate or shelter in place in response to releases of ammonia from the refrigeration system.

Issued

Oct 8, 2021

Abate by

Mar 15, 2022

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.120(q)(1): The employer, who would evacuate employees from the danger area when an emergency occurred and would not permit any employees to assist in handling the emergency, did not provide an emergency action plan in accordance with 1910.38:  (a) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, the employer does not have an emergency response plan and their emergency action plan does not include adequate procedures for sheltering in place in accordance with the requirements of 29 CFR 1910.38(c)(2), the facility does not use a distinctive signal for each purpose identified in the emergency action plan in accordance with the requirements of 29 CFR 1910.38(d), and the facility does not have established procedures for sounding emergency alarms in the workplace for each purpose identified in the emergency action plan in accordance with the requirements of 29 CFR 1910.165(b)(5).

Issued

Oct 8, 2021

Abate by

Mar 15, 2022

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR  1910.165(b)(5): Procedures were not established for sounding emergency alarms in the workplace:  (a) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, the facility's procedure for informing employees as to whether they are to evacuate or shelter in place in response to releases of ammonia from the refrigeration system relies upon direct voice communication.

Issued

Oct 8, 2021

Abate by

Nov 15, 2021

Penalty

Initial $5,851 · Current $2,000 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR  1910.147(c)(5)(ii): Lockout devices and tagout devices were not used for lockout and tagout purposes only:  (a) Location - 330 Ballardvale Street, Wilmington, MA:  On or about May 27, 2021, lockout locks and tags were used to prevent equipment operation for purposes unrelated to the control of hazardous energy during servicing and maintenance activities.