OSHA Inspection: UNITED DAIRY, INC.

Issued

Jun 27, 2023

Abate by

Jan 2, 2025

Penalty

Initial $15,625 · Current $8,300 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:  a) In the Engine Room, on or about January 18, 2023, the employer did not comply with their chosen recognized and generally accepted good engineering practices (RAGAGEP) ANSI/IIAR 2 - 2008 Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigerating Systems, Section 13.2.1.3, because there is not a supervised alarm system activated when their mechanical ventilation system fails.  b) In the Engine Room, on or about January 18, 2023, the employer did not comply with their chosen recognized and generally accepted good engineering practices (RAGAGEP) ANSI/IIAR 2 - 2008 Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigerating Systems, Section 13.2.1.4, because there are no emergency remote controls for the mechanical ventilation system located outside the Engine Room.    c) In the Engine Room, on or about January 18, 2023, the employer did not comply with their chosen recognized and generally accepted good engineering practices (RAGAGEP) ANSI/IIAR 2 - 2008 Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigerating Systems, Section 13.2.3.1, because their Engine Room ammonia detection system does not actuate the two emergency up blast fans.  d) In the Engine Room, on or about January 18, 2023, the employer did not comply with their chosen recognized and generally accepted good engineering practices (RAGAGEP) ANSI/IIAR 2 - 2008 Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigerating Systems, Section 13.2.3.2, because their continuously run ventilation fans did not provide a total ventilation rate at least equal to the larger of the two rates in Section 13.2.3.3.   e) In the Engine Room, on or about January 18, 2023, the employer did not comply with their chosen recognized and generally accepted good engineering practices (RAGAGEP) ANSI/IIAR 2 - 2008 Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigerating Systems, Section 13.2.3.4, because the normal (non-emergency) ventilation rate does not provide normal ventilation volumes equal to the larger of the volumes in Section 13.2.3.4.  f) In the Engine Room, on or about January 18, 2023, the employer did not comply with their chosen recognized and generally accepted good engineering practices (RAGAGEP) ANSI/IIAR 2 - 2008 Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigerating Systems, Section 13.2.3.9, because an Engine Room intake louvre is positioned adjacent to the air compressor exhaust fan discharge.  Failure to ensure that the Engine Room mechanical ventilation system complies with their chosen RAGAGEP can result in employee exposure to anhydrous ammonia while inside the Engine Room. Exposure to ammonia can result in inhalation hazards which can result in serious injuries or death.

Issued

Jun 27, 2023

Abate by

Jan 2, 2025

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 class of location:  a) The Engine Room, on or about January 18, 2023, contained standard electrical equipment that was not approved for the class of location. The Engine Room is classified as a Class I, Group D, Division 2 location because the employer's mechanical ventilation system was not operated according to either Sections 13.2.3.1 or 13.2.3.2 of their chosen recognized and generally accepted good engineering practices (RAGAGEP) ANSI/IIAR 2 - 2008 Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigerating Systems. Failure to ensure that electrical equipment is approved for the class of location can result in employee exposure to anhydrous ammonia fire and explosion hazards in the Engine Room which can result in serious injuries or death.

Issued

Jun 27, 2023

Abate by

Oct 30, 2023

Penalty

Initial $15,625 · Current $8,400 Reduced

General-duty citation text

29 CFR  1910.119(j)(2): The employer did not establish and implement written procedures to maintain the on-going integrity of process equipment:  a) In the Engine Room, on or about January 18, 2023, the employer failed to establish written procedures to maintain the on-going integrity of process equipment, when the employer's written procedures, "System Entire Maintenance Procedure Ammonia Flanges, Fittings, and Pipe," "IIAR-109 Inspection_Pressure Vessels," "IIAR-109 Inspection Piping Systems," and "UNITED DAIRY, UNIONTOWN DIVISION UNIONTOWN FACILITY RECOGNIZED AND GENERALLY ACCEPTED GOOD ENGINEERING PRACTICES STATEMENT," did not include specific procedural steps or instructions to assure the mechanical integrity of anhydrous ammonia pressure vessels, piping systems, and pressure relief valves. Failure to inspect, test, and maintain anhydrous ammonia vessels, piping systems, and pressure relief valves can lead to loss of containment and expose employees to toxic and fire hazards.

Issued

Jun 27, 2023

Abate by

Oct 30, 2023

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 was not consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience:  a) In the Engine Room, on or about January 18, 2023, the frequency of inspections of anhydrous ammonia refrigeration system process equipment was not consistent with Bulletin No. 109 Guidelines for: IIAR Minimum Safety Criteria for a Safe Ammonia Refrigeration System, Section 5.3, because a more thorough inspection of the ammonia refrigeration system was not conducted every five years.  The employer selected the bulletin to use as guidelines for their in-depth inspection of critical refrigeration equipment. Failure to inspect anhydrous ammonia refrigeration system process equipment at appropriate frequency can lead to loss of containment and exposure to toxic and fire hazards.

Issued

Jun 27, 2023

Abate by

Aug 14, 2023

Penalty

Initial $15,625 · Current $8,300 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 did not document that deficiencies had been corrected:  a) In the Facility, on or about January 18, 2023, the employer did not promptly document the corrections for deficiencies (items listed below) identified in their 2022 compliance audit, exposing employees to fire and toxic hazard posed by anhydrous ammonia in the event of an uncontrolled release.    (a) Item 1: Update the maximum intended inventory to include new equipment (chiller and cooler evaporators)  (b)	Item 2: Update the materials of construction document to only include equipment currently in the process.  (c)	Item 3: Archive P&IDs of equipment no longer in service to prevent confusion.   (d)	Item 4: Update the Design Codes and Standard to replace Bulletin 109 with IIAR 6.  Consider adding date of code (year) for others.  (e)	Item 5: Update the material and energy balance to include new equipment (chiller and evaporators).   (f)	Item 6: Update the Recognized and Generally Accepted Good Engineering Practice (RAGAGEP) to replace B109 reference with IIAR 6.  (g)	Item 7: Ensure an operator level (hourly) employee is included on the PHA team for the 2024 PHA revalidation.   (h)	Item 8: Verify SOP Training refresher is completed for all operators.  (i)	Item 9: Complete a contractor qualification document for Woods Refrigeration on an annual basis.  (j)	Item 10: Verify all SOP refresher training is brought up to date.  (k)	Item 11: Verify annual inspection documents (B109 or IIAR 6) exist for last 5 years. If not, develop program to ensure annual inspections are performed and documented.  This is an ongoing hazardous condition that can result in the release of ammonia causing serious injury to employees.  (l)	Item 12: Adopt IIAR 6 as a template for frequency of tests on covered equipment.  This is an ongoing hazardous condition that can result in the release of ammonia causing serious injury to employees.  (m)	Item 13: Adopt IIAR 6 inspection templates to document tests and inspections.  This is an ongoing hazardous condition that can result in the release of ammonia causing serious injury to employees.  (n)	Item 14: Verify hot work permit/program dictates a minimum 60-minute fire watch per NFPA 51B-2019.  (o)	Item 15: Ensure/verify procedures for inspection/testing/maintenance for respirators exist or are developed.  (p)	Item 16: Document annual coordinated training with local responders per the EAP (section M) 2. Document training on the EAP for all personnel in the plant.  (q)	Item 17: Engine Room 1 - Install NFPA (3-3-0) Placards and proper signage on machine room doors. 2. Install NFPA placard on door to receiver 1 (under condensers).  (r)	Item 18: Engine Room: Consider developing a plan to eliminate cut and capped equipment from the machine room to help with housekeeping measures.  (s)	Item 19: Roof Area (as applicable): Consider developing secondary egress from roof areas to prevent anyone from possibly being trapped on roof in an emergency.  (t)	Item 20: Roof Area (as applicable): Fill gap on condenser platform that could allow someone to fall.   (u)	Item 21: Roof Area (as applicable):  1. Install pipe labels on all uninsulated exterior piping around the chilled tanks. 2. Label surge drum and piping on vessel nearest compactors. 3. Install labels on ammonia vessels and piping on sweet water tanks. 4. Install labels on HSD piping and CD piping around both condensers.  (v)	Item 22: Roof Area (as applicable): Remove growth of weeds on roof under ammonia piping.  (w)	Item 23: Ammonia Alarms:  1. Install ammonia alarm audible and visual alarm at the Emergency Stop button box outside of the machine room. 2. Install manual ventilation control switch at the Emergency stop box.  This is an ongoing hazardous condition that can result in the release of ammonia causing serious injury to employees.  (x)	Item 24: Remove the PRVs on the condenser (if appropriate). If they remain on condenser, the relief should be pointed straight up with a means to prevent water from entering