OSHA Inspection: KUNZLER & COMPANY, INC.

Issued

2023-09-11 00:00:00

Abate by

2024-03-01 00:00:00

Penalty

Initial $12278.00 · Current $6300.00 Reduced

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer did not include all equipment that was part of the process on piping and instrument diagrams:  a. Engine room - On or about March 13, 2023, the employer failed to document the valves, gages, sight glasses, and controls on screw compressor RC 1. Failure to have accurate P&IDs could result in human error during operations and maintenance and employees not being able to identify or locate equipment in the event of an emergency resulting in exposure to anhydrous ammonia vapors and liquid.  b. Engine room - On or about March 13, 2023, the employer failed to document the valves, gages, sight glasses, and controls on screw compressor RC 2. Failure to have accurate P&IDs could result in human error during operations and maintenance and employees not being able to identify or locate equipment in the event of an emergency resulting in exposure to anhydrous ammonia vapors and liquid.  c. Engine room - On or about March 13, 2023, the employer failed to document the valves, gages, sight glasses, and controls on screw compressor RC 3. Failure to have accurate P&IDs could result in human error during operations and maintenance and employees not being able to identify or locate equipment in the event of an emergency resulting in exposure to anhydrous ammonia vapors and liquid.  d. Engine room - On or about March 13, 2023, the employer failed to document the valves, gages, sight glasses, and controls on screw compressor RC 4. Failure to have accurate P&IDs could result in human error during operations and maintenance and employees not being able to identify or locate equipment in the event of an emergency resulting in exposure to anhydrous ammonia vapors and liquid.  e. Engine room - On or about March 13, 2023, the employer failed to document the valves, gages, sight glasses, and controls on screw compressor RC 5. Failure to have accurate P&IDs could result in human error during operations and maintenance and employees not being able to identify or locate equipment in the event of an emergency resulting in exposure to anhydrous ammonia vapors and liquid.  f. Engine room - On or about March 13, 2023, the employer failed to document the valves, gages, sight glasses, and controls on screw compressor RC 6. Failure to have accurate P&IDs could result in human error during operations and maintenance and employees not being able to identify or locate equipment in the event of an emergency resulting in exposure to anhydrous ammonia vapors and liquid.  g. Building 2 west 2nd floor - On or about March 13, 2023, the employer had identified in the field Air Unit (AU) 89A as AU 88A on the P&ID's however the associated valves were still tagged as 89A on P&ID 22.3. Failure to have accurate P&IDs could result in human error during operations and maintenance and employees not being able to identify or locate equipment in the event of an emergency resulting in exposure to anhydrous ammonia vapors and liquid.  h. Behind building 2 - On or about March 13, 2023, the employer had not identified on the P&ID 22.3 the pump recirculation package there were 2 gages, 3 valves and an unknown item that was completely iced over. Failure to have accurate P&IDs could result in human error during operations and maintenance and employees not being able to identify or locate equipment in the event of an emergency resulting in exposure to anhydrous ammonia vapors and liquid.

Issued

2023-09-11 00:00:00

Abate by

2024-03-01 00:00:00

Penalty

Initial $12278.00 · Current $15600.00

General-duty citation text

OSH ACT of 1970 Section (5)(a)(1)  The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees    a. Roof/PSI - On or about March 13, 2023, the employer did not document that equipment compiled with RAGAGEPs such as Pennsylvania Mechanical Code Chapter 3, section 306.1 and 306.5 to ensure personnel required to maintain equipment on the roof had access to the compressor EC3 for maintenance and emergency response. Failure to access process equipment, relief devices and systems in the event of an emergency can lead to catastrophic failure of pressure vessels, piping exposing employees to struck by, fall, toxic, and fire hazards.  b. Throughout the facility - On or about March 13, 2023, the employer did not document that equipment compiled with the employer's chosen RAGAGEP IIAR 2 (2021), Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems Section 5.14.2 for the marking of piping circuits. Failure to mark pipes with content and phase can lead to unexpected release of ammonia in liquid or gaseous state which may result in employee exposure to toxic and fire hazards.  c. Outside Engine Room - On or about March 13, 2023, the employer did not document that equipment compiled with the employer's chosen RAGAGEP, IIAR 2 (2021), Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems Section 6. 7 .2, and ANSI/ISEA Z358.1 (2014), Sections 5.4.1 and 5.4.2, when employees did not have an accessible external eyewash and body shower unit located within 50 ft. or 10 seconds of the engine room. Failure to install an eyewash and shower can lead to chemical burns and eye injury from ammonia exposure.  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

2023-09-11 00:00:00

Penalty

Initial $15625.00 · Current $15600.00 Reduced

General-duty citation text

OSH ACT of 1970 Section (5)(a)(1)  The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees   a. Engine Room - On or about March 13, 2023, the employer had not established and implemented a written operating procedure for draining oil from the system. By failing to develop and implement effective written procedures for draining oil from the system, employees were exposed to respiratory distress, eye, and nasal irritation, nausea, vomiting and acute over exposure sickness.  Corrected During Inspection

Issued

2023-09-11 00:00:00

Abate by

2024-03-01 00:00:00

Penalty

Initial $12278.00 · Current $6200.00 Reduced

General-duty citation text

29 CFR 1910.119(f)(4): The employer did not develop or implement safe work practices for control over entrance into the covered process area by maintenance, contractor, laboratory, or other support personnel.   a. Engine Room - On or about March 13, 2023, the employer failed to develop and implement policies and procedures to control access to engine room by maintenance personnel, non-PSM management, support personnel, visitors/inspectors, and contractors in accordance with IIAR 2, Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems Section 6.3.3. Failure to limit access to process equipment, relief devices and systems can lead to catastrophic failure of pressure vessels, piping and employee exposure to toxic, fire, and explosion hazards.  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

2023-09-11 00:00:00

Abate by

2024-03-01 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.119(h)(2)(iv): The employer did not develop and implement safe work practices consistent with paragraph (f)(4) of this section to control the entrance, presence and exit of contract employers and contract employees in the covered process areas.   a. Engine Room - On or about March 13, 2023, the employer failed to develop and implement policies and procedures to control access to engine room by contractors in accordance with IIAR 2, Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems Section 6.3.3. Failure to limit access to process equipment, relief devices and systems can lead to catastrophic failure of pressure vessels, piping and employee exposure to toxic, fire, and explosion hazards.  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

2023-09-11 00:00:00

Abate by

2024-03-01 00:00:00

Penalty

Initial $15625.00 · Current $6300.00 Reduced

General-duty citation text

29 CFR 1910.119(j)(4)(i): The employer did not perform inspection and tests on process equipment.   a. Engine Room - On or about March 12, 2023, the employer failed to perform calibration testing and maintenance of ammonia sensors in the engine room which made prevented emergency responders and the site Hazwoper team from being able to ascertain the concentration and hazard within the engine room. Failure to maintain process equipment, valves, controllers, relief devices and systems can lead to catastrophic failure of pressure vessels, piping and employee exposure to toxic, fire, and explosion hazards.  b. Engine Room - On or about March 12, 2023, the employer failed to perform routine maintenance, inspections, tests and replacement of TX3 thermal expansion valves and solenoid valves in accordance with manufacturers specifications or Pennsylvania Mechanical Code section 1109.1. Failure to maintain process equipment, valves, controllers, relief devices and systems can lead to catastrophic failure of pressure vessels, piping and employee exposure to toxic, fire, and explosion hazards.  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

2023-09-11 00:00:00

Abate by

2024-03-01 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.120(q)(2)(ii): The emergency response plan did not address, to the extent not addressed elsewhere, personnel roles, lines of authority, and communication:  a. Lancaster Pennsylvania Plant - On or about March 12, 2023, the employer failed to establish and implement a written emergency response plan in accordance with 1910.119(n) to include Personnel roles, lines of authority, training, and communication. The ERP does not identify who is assigned to the company emergency response team and only states "emergency response team members." Failure to develop and implement these procedures creates confusion during emergencies which exposes employees to hazards associated with the uncontrolled release of anhydrous ammonia's toxic vapors.  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.