OSHA Inspection: AMERICOLD LOGISTICS, LLC.

Issued

Aug 25, 2022

Abate by

Sep 21, 2022

Penalty

Initial $14,502 · Current $0 Reduced

General-duty citation text

29 CFR  1910.119(d)(3)(i)(D): Information pertaining to the equipment in the process did not include relief system design and design basis:  At the Wichita facility the employer had not developed nor implemented the relief system design or design basis for the equipment in the Ammonia refrigeration processes. The current provided process safety information was not detail, it only referred to the P&ID, there was no documentation of the relief system design and design basis for OSHA to evaluate to ensure the calculations, the designs are correct with the required codes in accordance with "American National Standard for Equipment, Design and Installation of Ammonia Mechanical Refrigeration Systems" sponsored by IIAR and approved by The American National Standards Institute. An overpressure/overtemperature could lead to the opening of the emergency relief devices and the accidental release of ammonia in the air. However, if the relief devices, the safety relief valves are not accurate, are not working properly when needed, then they could not protect personnel and/or equipment from over-pressure conditions. Employees were exposed to catastrophic release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injurie to persons in and near the facility.

Issued

Aug 25, 2022

Abate by

Sep 21, 2022

Penalty

Initial $14,502 · Current $0 Reduced

General-duty citation text

29 CFR  1910.119(d)(3)(i)(E): The employer did not have a compilation for written process safety information pertaining to the ventilation system design:   At the Wichita facility the employer did not verify that the engine room ventilation systems complied with recognized and generally accepted good engineering practices in that the ventilation calculations used for safety purposes to assure it performs at a rate specified in the design were not developed.  The current provided process safety information was not detail. It contains only half a page with a diagram to describe the engine room ventilation system. Employer did not provide the full detail ventilation system design for OSHA to evaluate to ensure the calculation, the design is correct and up to required codes of IIAR 2-2014 and ASHRAE 15-2013. Employees were exposed to catastrophic release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injury to persons in and near the facility.

Issued

Aug 25, 2022

Abate by

Sep 21, 2022

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.307(c)(2)(i): Equipment in hazardous (classified) location(s) was not approved for the ignitable or combustible properties of the specific gas, vapor, dust, or fiber that was or could be present:  At the Wichita facility the employer did not verify that the engine room ventilation systems complied with recognized and generally accepted good engineering practices in that the ventilation calculations used for safety purposes to assure it performs at a rate specified in the design were not developed, and machinery engine room contains standard/regular electrical equipment. The current provided process safety information was not detail. It contains only half a page with a diagram to describe the engine room ventilation system. Employer did not provide the full detail ventilation system design for OSHA to evaluate to ensure the calculation, the design is correct and up to required codes. Therefore, the electrical equipment inside the engine room, normally designated as Class I, Division 2 of the National Electrical Code requiring explosion proof electrical equipment, are not exempt by the exhaust fan and continuously ventilation system defined in ASHRAE 15-2010, Section 8.12(h). Employees were exposed to catastrophic release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injury to persons in and near the facility.

Issued

Aug 25, 2022

Penalty

Initial $14,502 · 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:  At the Wichita facility the employer failed to document that equipment complied with recognized and generally accepted good engineering practices (RAGAGEP) when the employer did not ensure ammonia refrigeration valves were labeled. Employees engaged in repairing, replacing, operating, inspecting, testing, and maintenance activities of covered process equipment in the engine rooms were exposed to the hazards of inhalation of toxic ammonia, asphyxiation, chemical burns, and fire.  The following was noted during the walk around inside the engine room on March 08, 2022: a) A valve was missing the Valve Identification Tags for the suction valve located by CP-8. b) A valve was missing the Valve Identification Tags for the float column valve located by V-2, Intercooler #1. c) Two valves were missing the Valve Identification Tags for the float valve located by V-5, Intercooler #2. d) A valve was missing the Valve Identification Tags for the stop valve located by the Oil-pot V-5. e) A valve was missing the valve Identification Tags for the suction valve located by CP-7.

Issued

Aug 25, 2022

Abate by

Sep 21, 2022

Penalty

Initial $14,502 · Current $0 Reduced

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:  At the Wichita facility, at the time of the inspection, the employer did not provide document to show that they have performed an initial process hazard analysis (hazard evaluation) on processes except for the two most current 2013 and 2018 Process Hazard Analysis. Employees were exposed to catastrophic release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injurie to persons in and near the facility.

Issued

Aug 25, 2022

Abate by

Sep 21, 2022

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.119(e)(6): The employer did not update and revalidate by a team meeting the requirements in paragraph (e)(4) of this section, to assure that the process hazard analysis is consistent with the current process, at least every five (5) years after the completion of the initial process hazard analysis:  At the Wichita facility, at the time of the inspection, the employer did not provide document to show that they have performed the revalidation at least every five (5) years, except for the two most current 2013 and 2018 Process Hazard Analysis. The employer did not update and revalidate the Process Hazard Analysis for the refrigeration system at least every five years to assure that the Process Hazard Analysis for the ammonia refrigeration processes is consistent with the current process, from the required of May 1997 when all the initial Process Hazard Analysis shall be completed to the present, except for 2013 and 2018. Employees were exposed to catastrophic release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injurie to persons in and near the facility.

Issued

Aug 25, 2022

Abate by

Sep 21, 2022

Penalty

Initial $14,502 · Current $0 Reduced

General-duty citation text

29 CFR  1910.119(e)(3)(i): The Process Hazard Analysis did not address the hazards of the process:   At the Wichita facility, at the time of the inspection, the two most current 2013 and 2018 Process Hazard Analysis (PHA) did not address the hazards of the process in that the ammonia incoming/inbounding was not addressed in these two PHA reports or the What-If checklists. Employees were exposed to catastrophic release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injurie to persons in and near the facility.

Issued

Aug 25, 2022

Abate by

Sep 21, 2022

Penalty

Initial $14,502 · Current $0 Reduced

General-duty citation text

29 CFR  1910.119(f)(1): The employer did not develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process:  At the Wichita facility the employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process. Employees engaged in repair, replace, inspection and maintenance activities of covered process equipment at the engine rooms, roof top, and the warehouse, freezer areas were exposed to the hazards of inhalation of toxic ammonia, asphyxiation, chemical burns, and fire. The review of the Standard Operating Procedures (SOP) showing some of the following deficiencies: a. The Ammonia Pumps #2 (PP2) Standard Operating Procedure (SOP) was deficient in that the Process Piping & Instrumentation Diagrams (P&ID) was referenced without the ID, the drawing, or the control number. The Technical Operating Specification / Node Description Ammonia Pumps #2 (PP2) - Instrumentation and Safety Systems, Item Number section just listed, stated "See P&ID", therefore, it is not clear with which P&ID they refer to, what the drawing number, control number for the P&ID to review, to take actions in case of emergency. b. The Compressor Vilter #2 (CP2) Operating Procedure, Emergency Shutdown, Step #2, "Follow the procedures for 'normal shutdown' as listed above." There was no mention, no clear instructions of how and when with related to the intended use of the emergency stop devices (the emergency shutdown button) installed outside of the engine room. The employer did not develop a clear instruction in the Compressor Vilter #2 (CP2) Standard Operating Procedure Emergency Shutdown section as to when/what conditions, how and who is authorized to activate the Ammonia Emergency Shutdown procedure. There was no description, provision describing conditions requiring emergency shutdown of the system. c. The Compressor Vilter #2 (CP2) Standard Operating Procedure (SOP) was deficient in that the Process Piping & Instrumentation Diagrams (P&ID) was referenced without the ID, the drawing, or the control number. The Technical Operating Specification / Node Description Compressor Vilter #2 (CP2) - Instrumentation and Safety Systems, Item Number section just listed, stated "See P&ID", therefore, it is not clear with which P&ID they refer to, what the drawing number, control number for the P&ID to review in case of emergency. d. The Condenser #2 (C2) Standard Operating Procedure (SOP) was deficient in that the Process Piping & Instrumentation Diagrams (P&ID) was referenced without the ID, the drawing, or the control number. The Technical Operating Specification / Node Description Condenser #2 (C2) - Instrumentation and Safety Systems, Item Number section just listed, stated "See P&ID", therefore, it is not clear with which P&ID they refer to, what the drawing number, control number for the P&ID to review in case of emergency. e. The Evaporators CD East (AU4) Standard Operating Procedure (SOP) was deficient in that the Process Piping & Instrumentation Diagrams (P&ID) was referenced without the ID, the drawing, or the control number. The Technical Operating Specification / Node Description Evaporators CD East (AU4) - Instrumentation and Safety Systems, Item Number section just listed, stated "See P&ID", therefore, it is not clear with which P&ID they refer to, what the drawing number, control number for the P&ID to review in case of emergency. f. The Exhaust Fan #2 Standard Operating Procedure (SOP) was deficient in that the Process Piping & Instrumentation Diagrams (P&ID) was referenced without the ID, the drawing, or the control number. The Technical Operating Specification / Node Description Exhaust Fan #2 - Instrumentation and Safety Systems, Item Number section just listed, stated "See P&ID", therefore, it is not clear with which P&ID they refer to, what the drawing number, control number for the P&ID to review in case of emergency. g. The LTR #1 (V1) Operating Procedure, Emergency Shutdown Instructions / Required Steps.  Step 1. Shut down compressors. The SOP did not list out step by step on how, what are the steps to shut down the compressors such as shut down by the compressor panels inside the engine room or by the emergency stop button outside the exit of the engine room. There was no mention, no clear instructions of how with related to the intended use of the emergency stop devices (the emergency shutdown button) installed outside of the engine room.  Step 2. If the emergency is an ammonia leak, turn off all flow promoting equipment then close valves deemed appropriate per the P&ID's. There was no specific of which P&ID to work with in case of ammonia leak. h. The LTR #1 (V1) Standard Operating Procedure (SOP) was deficient in that the Process Piping & Instrumentation Diagrams (P&ID) was referenced without the ID, the drawing, or the control number. The Technical Operating Specification / Node Description LTR #1 (V1) - Instrumentation and Safety Systems, Item Number section just listed, stated "See P&ID", therefore, it is not clear with which P&ID they refer to, what the drawing number, control number for the P&ID to review in case of emergency.  The SOP procedural steps instruct employees to verify valve conditions, to open, close, or shut valves during operations, or emergency situations. Because of this reason, the P&ID must be identified in each of the SOP to be able to reference quickly, and to avoid confusion, the instruction steps must be clear. Employees and contractors must immediately know what valves to open and close, which P&ID to review, to identity, to work with, what steps to follow, which one to shut down in case of emergency. Safety systems are critical to ensure that the process remains under control within operating limits, and will shut down under unsafe conditions of temperature, pressure, or flow. The data in the Process Safety Information is essential for the Mechanical Integrity program for the safety equipment.

Issued

Aug 25, 2022

Abate by

Sep 21, 2022

Penalty

Initial $14,502 · Current $0 Reduced

General-duty citation text

29 CFR  1910.119(f)(1)(iii)(D): The employer's written operating procedures covering operating limits did not address quality control for raw materials and control of hazardous chemical inventory levels:   At the Wichita facility the employer did not address quality control for raw materials and control of hazardous chemical inventory levels within the current written operating procedures. Employees engaged in repair, replace, inspection, testing and maintenance activities of covered process equipment at the engine rooms, roof top, and the warehouse, freezer areas were exposed to the hazards of inhalation of toxic ammonia, asphyxiation, chemical burns, and fire. Identified operating procedures such as but not limited to the following: a) SOP Ammonia Pumps: Ammonia Pump #2 (PP2) - Reviewed/Certified on June 8, 2021, Issued on 8/25/2015 and Revised on 10/28/2015. b) SOP Compressors: Vilter #2 (CP2) - Reviewed/Certified on June 8, 2021, Issued on 8/25/2015 and Revised on 9/2/2015. c) SOP Condensers: Condenser #2 (C2) - Reviewed/Certified on June 8, 2021, Issued on 8/25/2015 and Revised on 10/28/2015. d) SOP Evaporators: CD East (AU4) - Reviewed/Certified on June 16, 2021, Issued on 8/25/2015 and Revised on 10/6/2015. e) SOP Ventilation: Exhaust Fan #2 - Reviewed/Certified on June 8, 2021, Issued on 8/25/2015 and Revised on 7/26/2017. f) SOP Vessels: LTR #1 (V1) - Reviewed/Certified on Nov 24, 2021, Issued on 8/25/2015 and Revised on 1/8/2016.

Issued

Aug 25, 2022

Abate by

Sep 21, 2022

Penalty

Initial $14,502 · Current $0 Reduced

General-duty citation text

29 CFR  1910.119(h)(2)(i): The employer, when selecting a contractor, did not obtain and evaluate information regarding the contract employer's safety performance and program:  At the Wichita facility the employer did not obtain and evaluate the written safety and health programs of the contractor (Tanner Industries, Inc.) that delivers or unloads ammonia from a tank truck to the ammonia refrigeration system. The driver of a contractor participated in the unloading of ammonia into process tanks. Employees engaged in repair, replace, inspection, testing, and maintenance activities of covered process equipment at the engine rooms, roof top, and the warehouse, freezer areas were exposed to the hazards of inhalation of toxic ammonia, asphyxiation, chemical burns, and fire.

Issued

Aug 25, 2022

Abate by

Sep 21, 2022

Penalty

Initial $14,502 · Current $0 Reduced

General-duty citation text

29 CFR  1910.119(j)(2): The employer did not establish or implement written procedures to maintain the on-going integrity of process equipment:  At the Wichita facility the employer the employer did not establish and implement the detail written mechanical integrity program procedures to ensure the maintaining of the on-going integrity of process equipment such as pressure vessels, storage tanks; piping systems (piping components such as valves); relief and vent systems and devices; emergency shutdown systems; controls (monitoring devices and sensors, alarms, and interlocks);  pumps as identified below. The employer did not address specific task procedures for the inspection, testing, preventive maintenance, repairing, rerating, or replacing pressure vessels, receivers, piping, or materials and spare parts control; outlining responsibilities, authorizations, and approval for repairs, steps to accomplish for repairing or replacing equipment, frequency of replacement, employee training and qualifications, welding and heat treating requirements, inspection and testing after repair, and documentation requirements. Employees engaged in repair, replace, inspection and maintenance activities of covered process equipment at the engine rooms, roof top, and production floor areas were exposed to the hazards of inhalation of toxic ammonia, asphyxiation, chemical burns, and fire. a) Employer did not develop and implement a comprehensive written mechanical integrity procedure that addressed inspecting, testing, and evaluating of pressure vessels, piping for corrosion under the insulation and minimum wall thickness. b) Employer did not develop and implement a written mechanical integrity procedure for evaluating relief and vent systems and devices.

Issued

Aug 25, 2022

Abate by

Sep 21, 2022

Penalty

Initial $14,502 · Current $0 Reduced

General-duty citation text

29 CFR  1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment:  At the Wichita facility the employer did not perform and document inspections and tests on process equipment to ensure the maintaining of the on-going integrity of critical process equipment as identified below.  The employer did not provide any requested document for inspection and tests on process equipment conducted by Americold employees. The employer only supplied OSHA with the records of inspection and tests for the ammonia sensors, and the document of the 5-years Mechanical Integrity inspection reports along with the Non-destructive testing (NDT) conducted by independent contractors. Employees engaged in repair, replace, inspection and maintenance activities of covered process equipment at the engine rooms, roof top, and production floor areas were exposed to the hazards of inhalation of toxic ammonia, asphyxiation, chemical burns, and fire. a) Inspection and testing was not performed and document for vessels and tanks such as Evaporators, High Pressure Receivers, and Condensers to determine if there were any corrosion damage and to establish a corrosion rate for the vessel. b) Inspection and testing was not performed and document for piping systems, corrosion under the insulation and minimum wall thickness. c) Inspection and testing was not performed and document for relief and vent systems and devices such as safety relief valves. d) Inspection and testing was not performed and document for emergency shutdown systems including but not limited to the Compressor cutouts including discharge temperature, discharge pressure, oil temperature (upper and lower), oil sump temperature maximum, Accumulator high and low liquid level cutouts. Inspection and testing were not performed and document on emergency stop devices to ensure the equipment was in accordance with design specifications and operable in case of emergency. The emergency stop (e-stop) button for the engine room did not activate fans.  e) Inspection and testing were not performed and document for controls (including monitoring devices and sensors, level cutouts, alarms, and interlocks) such as Compressor liquid level control sensors, Compressor thermostats, Compressor liquid level controls, Pump out system level alarms.  f) Inspection and testing was not performed and document for Emergency Ventilation Systems used for safety purposes to assure it performs at a rate specified in the design, to ensure the equipment was in accordance with design specifications and operable in case of emergency. g) Inspection and testing was not performed and document for ammonia compressors and pumps to ensure the equipment was in accordance with design specifications to prevent worker exposure to an accidental anhydrous ammonia release and damage to equipment.

Issued

Aug 25, 2022

Abate by

Sep 21, 2022

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment to maintain its mechanical integrity, was not consistent with applicable manufacturer's recommendations and good engineering practices, or more frequently determined to be necessary by prior operating experience:  At the Wichita facility the employer did not document that inspections and tests have been performed and documented based on the appropriate inspection frequency as required by the applicable manufacturers' recommendations and good engineering practices (IIAR Bulletin 110-1993, and Bulletin 109-10/97) on process equipment to ensure the maintaining of the on-going integrity of critical process equipment as identified below.  The employer did not provide any requested document for inspection and tests on process equipment conducted by Americold employees. There were no document showing the frequency of inspections and tests of process equipment. They only supplied OSHA with the records of inspection and tests for the NH3 sensors, and the document of the 5-years Independent Mechanical Integrity full inspection reports along with the Non-destructive testing (NDT). Employees engaged in repair, replace, inspection and maintenance activities of covered process equipment at the engine rooms, roof top, and production floor areas were exposed to the hazards of inhalation of toxic ammonia, asphyxiation, chemical burns, and fire.  The following inspections were not document that they have been performed or conducted by Americold employees: a) There were no records showing various frequency inspections have been performed for the interval of weekly, monthly, bi-annually, and annually for the Evaporators. b) There were no records showing various frequency inspections have been performed for the interval of weekly, monthly, bi-annually, and annually for the High Pressure Receivers. c) There were no records showing various frequency inspections have been performed for the interval of weekly, monthly, bi-annually, and annually for the Condensers. d) There were no records showing various frequency inspections have been performed for the interval of daily to 72 hours, quarterly, bi-annually, and annually for the Compressors. e) There were no records showing various frequency inspections have been performed for the interval of monthly, and annually for the Ammonia Pumps.

Issued

Aug 25, 2022

Abate by

Sep 21, 2022

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.119(j)(4)(iv): The employer did not document each inspection and test that had been performed on process equipment. The documentation 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:  At the Wichita facility the employer did not document that inspections and tests being performed on process equipment to ensure the maintaining of the on-going integrity of critical process equipment as identified below.  The employer did not provide any requested document for inspection and tests on process equipment conducted by Americold employees. The employer only supplied OSHA with the records of inspection and tests for the ammonia sensors, and the document of the 5-years Mechanical Integrity inspection reports along with the Non-destructive testing (NDT) conducted by independent contractors. Employees engaged in repair, replace, inspection and maintenance activities of covered process equipment at the engine rooms, roof top, and production floor areas were exposed to the hazards of inhalation of toxic ammonia, asphyxiation, chemical burns, and fire.  The following inspections and tests were not document that they have been performed or conducted by Americold employees: a) Inspection and testing was not performed and document for vessels and tanks such as Evaporators, High Pressure Receivers, and Condensers to determine if there were any corrosion damage and to establish a corrosion rate for the vessel. b) Inspection and testing was not performed and document for piping systems, corrosion under the insulation and minimum wall thickness. c) Inspection and testing was not performed and document for relief and vent systems and devices such as safety relief valves. d) Inspection and testing was not performed and document for emergency shutdown systems including but not limited to the Compressor cutouts including discharge temperature, discharge pressure, oil temperature (upper and lower), oil sump temperature maximum, Accumulator high and low liquid level cutouts. e) Inspection and testing was not performed and document for controls (including monitoring devices and sensors, level cutouts, alarms, and interlocks) such as Compressor liquid level control sensors, Compressor thermostats, Compressor liquid level controls, Pump out system level alarms.  f) Inspection and testing were not performed and document Ammonia compressors and pumps.

Issued

Aug 25, 2022

Abate by

Sep 21, 2022

Penalty

Initial $14,502 · Current $0 Reduced

General-duty citation text

29 CFR  1910.119(l)(5): A change covered by this paragraph resulted in a change in the operating procedures or practices required by paragraph (f) of this section, and such procedures or practices were not updated accordingly:  At the Wichita facility the employer the employer did not update current standard operating procedures (SOP) and practices related to the installation and intended use of the emergency shutdown devices (emergency stop buttons) located outside of the engine room.  All the current emergency shutdown procedures within the standard operating procedures such as but not limited to the Compressor Vilter #2 (CP2) did not reflect any discussion about the emergency shutdown devices. The SOP procedural steps instruct employees to verify valve conditions, to open, close, or shut valves during operations, or emergency situations. Because of this reason the instructional steps must be clear. Employees and contractors must immediately know what valves to open and close, which P&ID to review, to identity, to work with, what steps to follow, which one to shut down in case of emergency. They have to know when to either stop the flow at the local compressor, or to shut down by pressing the emergency shutdown devices outside of the engine room. Safety systems are critical to ensure that the process remains under control within operating limits, and will shut down under unsafe conditions of temperature, pressure, or flow. Employees engaged in repair, replace, inspection and maintenance activities of covered process equipment at the engine rooms, roof top, and the warehouse, freezer areas were exposed to the hazards of inhalation of toxic ammonia, asphyxiation, chemical burns, and fire.

Issued

Aug 25, 2022

Abate by

Sep 21, 2022

Penalty

Initial $14,502 · Current $0 Reduced

General-duty citation text

29 CFR  1910.119(o)(1): The employer did not certify that they had evaluated compliance with provisions of 29 CFR 1910.119 at least every three years to verify that the procedures and practices developed under this standard were adequate and are being followed:  At the Wichita facility, at the time of the inspection, the employer did not provide document to show that they have performed the compliance audit at least every three (3) years, except for the Audit Report Wichita Compliance Audit 2018. The employer provided no certifications that it had performed compliance evaluations to verify that its procedures and practices developed under the standard are adequate and being followed for the 2015 or 2021 Compliance Audits. Employees were exposed to catastrophic release of ammonia which results in asphyxiation, explosion and flash fire leading to death and injurie to persons in and near the facility.