OSHA Inspection: MILLER ELECTRIC MFG. LLC

Issued

Apr 22, 2022

Abate by

Jun 30, 2022

Penalty

Initial $8,806 · Current $6,164 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(d)(3)(ii):  The employer shall document that equipment complies with recognized and generally accepted good engineering practices:  At an establishment located at 1635 West Spencer Street in Appleton, Wisconsin; the employer did not document that the Ice House emergency stop control system complies with recognized and generally accepted good engineering practices (RAGEGEP). The employer failed to document compliance with their chosen RAGEGEP including IIAR 9, when an E-Stop push-button and emergency ventilation control switch were not located outside the machinery room and adjacent to the designed principal engine room door. This hazardous condition potentially exposed employees to inhalation and burn hazards from ammonia liquid and vapors.

Issued

Apr 22, 2022

Abate by

Jun 1, 2022

Penalty

Initial $8,806 · Current $6,164 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(f)(1)(i)(D): The employer shall develop and implement written operating procedures that provide clear instructions and shall address steps for each operating phase including emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner:  At an establishment located at 1635 West Spencer Street in Appleton, Wisconsin; the employer's operating procedure addressing the Emergency Shutdown operating phase did not include the conditions under which emergency shutdown is required. The standard operating procedure "Ammonia Refrigeration System" did not contain descriptions, limitations, conditions or situations which would require HVAC employees to trigger an emergency shutdown of the ammonia refrigeration system.

Issued

Apr 22, 2022

Abate by

Jun 1, 2022

Penalty

Initial $8,806 · Current $0 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(j)(2): The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment:  At an establishment located at 1635 West Spencer Street in Appleton, Wisconsin; the employer did not establish or implement written procedures to maintain the on-going integrity of process equipment. The employer did not develop written procedures of sufficient detail to provide to the employers' inspectors (including contract inspectors) instruction on how to conduct inspection and test of the process equipment when:  a)  Basset Mechanical conducted annual mechanical integrity inspections on ammonia process equipment such as, but not limited to exhaust fans, the ammonia detector system, the control system, compressors, valves, and piping/vessels along with their respective insulation.  b)  Basset Mechanical and Miller Electric employee conducted monthly mechanical integrity inspection on ammonia process equipment such as, but not limited to compressors, vessels, pumps, and condensers.  c)  Basset Mechanical and a subcontractor (Janx Inspection most recently) conducted independent periodic corrosion under insulation (CUI) inspections of piping and vessels.  d)  Miller Electric employees conducted daily mechanical inspection on ammonia process equipment such as, but not limited to system pressures, compressors, vessels, pumps and heat exchangers.

Issued

Apr 22, 2022

Abate by

Jun 1, 2022

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(j)(4)(iv): The employer shall document each inspection and test that has been performed on process equipment. The documentation shall 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:   At an establishment located at 1635 West Spencer Street in Appleton, Wisconsin; the employer did not document each inspection that had been performed on the Ammonia Refrigeration System's (ARS) process equipment. Employees conducted daily inspections of the ARS's compressors, pumps, vessels, and heat exchangers. However, employees were only required to document the daily inspections on Mondays, Wednesdays, and Fridays on the "Miller Electric System Log Sheet". Employees were not documenting every daily inspection they conducted.