OSHA Inspection: HK COOPERATIVE, INC.

Issued

Jun 17, 2024

Abate by

Oct 1, 2024

Penalty

Initial $12,676 · Current $6,819 Reduced

Hazardous substances 8111

General-duty citation text

29 CFR  1910.95(d)(1):When information indicated that any employee's exposure equaled or exceed the 8-hour time-weighted average of 85 decibels, the employer did not develop and implement a monitoring program:  HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;  On or about January 4, 2024, the employer did not develop and implement a monitoring program for employees who were exposed to noise levels above an 8-hour time-weighted average of 85 dBA. Employees working in areas such as, but not limited to, the cut floor, kill floor, and conversion were exposed to hazards associated with high noise levels such as, but not limited to, hearing loss and tinnitus.  Instance A  On March 19, 2024, an employee, line lead in conversion, was exposed to noise at 109.1% of the permissible daily dose, or an average sound level of 91.2 decibels, as measured over 447 minutes of sampling. This dose is equivalent to an 8-hour TWA exposure of 90.6 decibels accounting for the period of 33 minutes unmonitored.   Instance B   On March 19, 2024, an employee, lead on cut floor, was exposed to noise at 115.4% of the permissible daily dose, or an average sound level of 92.9 decibels, as measured over 369 minutes of sampling. This dose is equivalent to an 8-hour TWA exposure of 91.0 decibels accounting for the period of 111 minutes unmonitored.   Instance C  On March 19, 2024, an employee, lead on kill floor, was exposed to noise at 156.5% of the permissible daily dose, or an average sound level of 94.0 decibels, as measured over 432 minutes of sampling. This dose is equivalent to an 8-hour TWA exposure of 92.4 decibels accounting for the period of 48 minutes unmonitored.

Issued

Jun 17, 2024

Abate by

Oct 1, 2024

Penalty

Initial $12,676 · Current $6,819 Reduced

Hazardous substances 8111

General-duty citation text

29 CFR  1910.95(g)(1):The employer did not establish and maintain an audiometric testing program as provided by 29 CFR 1910.95(g) by making audiometric testing available to all employees whose exposures equal or exceed an 8-hour time-weighted average of 85 decibels:  HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;  On or about January 4, 2024, the employer did not establish an audiometric testing program for employees who were exposed to noise levels above an 8-hour time-weighted average of 85 dBA. Employees working in areas such as, but not limited to, the cut floor, kill floor, and conversion were exposed to hazards associated with high noise levels such as, but not limited to, hearing loss and tinnitus.  Instance A  On March 19, 2024, an employee, line lead in conversion, was exposed to noise at 109.1% of the permissible daily dose, or an average sound level of 91.2 decibels, as measured over 447 minutes of sampling. This dose is equivalent to an 8-hour TWA exposure of 90.6 decibels accounting for the period of 33 minutes unmonitored.  Instance B   On March 19, 2024, an employee, lead on cut floor, was exposed to noise at 115.4% of the permissible daily dose, or an average sound level of 92.9 decibels, as measured over 369 minutes of sampling. This dose is equivalent to an 8-hour TWA exposure of 91.0 decibels accounting for the period of 111 minutes unmonitored.   Instance C  On March 19, 2024, an employee, lead on kill floor, was exposed to noise at 156.5% of the permissible daily dose, or an average sound level of 94.0 decibels, as measured over 432 minutes of sampling. This dose is equivalent to an 8-hour TWA exposure of 92.4 decibels accounting for the period of 48 minutes unmonitored.

Issued

Jun 17, 2024

Abate by

Oct 1, 2024

Penalty

Initial $12,676 · Current $6,819 Reduced

Hazardous substances 8111

General-duty citation text

29 CFR  1910.95(k)(1):The employer did not institute a training program and ensure employee participation in the program:  HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;  On or about January 4, 2024, the employer did not ensure a training program was instituted to ensure employees were informed of the following: (1) the effects of noise on hearing, (2) the purpose of hearing protectors, the advantages, disadvantages, and attenuation of various types, and instructions on selection, fitting, use, and care, and (3) the purpose of audiometric testing, and an explanation of the test procedures.  Employees working in areas such as, but not limited to, the cut floor, kill floor, and conversion were exposed to hazards associated with high noise levels such as, but not limited to, hearing loss and tinnitus.  Instance A  On March 19, 2024, an employee, line lead in conversion, was exposed to noise at 109.1% of the permissible daily dose, or an average sound level of 91.2 decibels, as measured over 447 minutes of sampling. This dose is equivalent to an 8-hour TWA exposure of 90.6 decibels accounting for the period of 33 minutes unmonitored.   Instance B   On March 19, 2024, an employee, lead on cut floor, was exposed to noise at 115.4% of the permissible daily dose, or an average sound level of 92.9 decibels, as measured over 369 minutes of sampling. This dose is equivalent to an 8-hour TWA exposure of 91.0 decibels accounting for the period of 111 minutes unmonitored.   Instance C  On March 19, 2024, an employee, lead on kill floor, was exposed to noise at 156.5% of the permissible daily dose, or an average sound level of 94.0 decibels, as measured over 432 minutes of sampling. This dose is equivalent to an 8-hour TWA exposure of 92.4 decibels accounting for the period of 48 minutes unmonitored.

Issued

Jun 17, 2024

Abate by

Jun 2, 2025

Penalty

Initial $16,131 · Current $8,678 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(d)(3)(i)(E): The employer did not have a compilation of written process safety information pertaining to the ventilation system design.   HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;  Instance A  On or about January 4, 2024, the employer did not ensure the process safety information included information pertaining to the equipment in the process. The information pertaining to the design of the ventilation systems installed on the west engine room was not documented, including but not limited to information pertaining to emergency shutdown controls. Employees were exposed to hazards associated with anhydrous ammonia refrigeration systems such as, but not limited to, corrosive burns, eye damage, fire, and explosion. Instance B  On or about January 4, 2024, the employer did not ensure the process safety information included information pertaining to the equipment in the process. The information pertaining to the design of the ventilation systems installed on the east engine room was not documented, including but not limited to information pertaining to emergency shutdown controls. Employees were exposed to hazards associated with anhydrous ammonia refrigeration systems such as, but not limited to, corrosive burns, eye damage, fire, and explosion.

Issued

Jun 17, 2024

Abate by

Feb 3, 2025

Penalty

Initial $16,131 · Current $8,678 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(e)(3)(i): The process hazard analysis did not address the hazards of the process.   HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;  On or about January 4, 2024, the employer failed to address the hazards of the process in the process hazard analysis (PHA) for a release going undetected in that employees operating the ammonia refrigeration process were exposed to undetected ammonia releases without the employer having adequate controls which could result in employees being exposed to a process with uncontrolled hazards which could result in contact with fire and explosion from an uncontrolled release of anhydrous ammonia and oil from the ammonia refrigeration equipment in the machine rooms.

Issued

Jun 17, 2024

Abate by

Feb 3, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(e)(5):The employer did not assure that PHA recommendations were resolved in a timely manner:  HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;  On or about January 4, 2024, the employer did not document resolutions to recommendations identified in the process hazard analysis (PHA) to assure the items were resolved in a timely manner and that the resolution was documented, develop a written schedule to complete actions as soon as possible, complete the actions as soon as possible, and communicate actions to operating/maintenance employees. Employees were exposed to hazards associated with anhydrous ammonia refrigeration systems such as, but not limited to, corrosive burns, eye damage, fire, and explosion.

Issued

Jun 17, 2024

Abate by

Feb 3, 2025

Penalty

Initial $16,131 · Current $8,678 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(g)(1)(i):The employer did not train each employee before being involved in operating a newly assigned process in the operating procedures as specified in paragraph (f) of this section:  HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;  On or about January 4, 2024, the employer did not ensure employees involved in operating a PSM covered process were provided with training in an overview of the process, operating procedures, specific safety and health hazards, emergency operations, and safe work practices. Employees performing walkaround inspections during normal operations, restarting compressors, and adjusting temperatures in the refrigeration bays were exposed to hazards associated with anhydrous ammonia refrigeration systems such as, but not limited to, corrosive burns, eye damage, fire, and explosion.

Issued

Jun 17, 2024

Abate by

Feb 3, 2025

Penalty

Initial $16,131 · Current $8,678 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(j)(2):The employer did not implement written procedures to maintain the on-going integrity of process equipment:  HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;  Instance A   On or about January 4, 2024, the employer did not establish written procedures to maintain the on-going integrity of process equipment. Procedures were not developed for the inspection and maintenance of ammonia gas sensors. Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion in the ammonia sensors in the east engine room were nonfunctioning.    Instance B  On or about January 4, 2024, the employer did not establish written procedures to maintain the on-going integrity of process equipment. Procedures were not developed for the inspection and maintenance of dual safety pressure relief valves installed on the oil separators of the screw compressors. Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion, in that the pressure relief valves of compressors in the west and east engine room were beyond their tagged replace by dates.   Instance C  On or about January 4, 2024, the employer did not establish written procedures to maintain the on-going integrity of process equipment. Procedures were not developed for the inspection and maintenance emergency shutdown buttons. Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion, in that the emergency shutdown buttons on the east engine room were not operational.   Instance D  On or about January 4, 2024, the employer did not establish written procedures to maintain the on-going integrity of process equipment. Procedures were not developed for the inspection and maintenance of pressure vessels and piping associated with the ammonia refrigeration systems. Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion, in that equipment such as but not limited to,  the high stage accumulator located in the west engine room and the associated piping showed evidence of deterioration of insulation and surface pitting.

Issued

Jun 17, 2024

Abate by

Feb 3, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(j)(4)(i): The employer did not perform inspections and tests on process equipment:  HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;  Instance A  On or about January 4, 2024, the employer did not perform inspections and testing on ammonia gas sensors in the east engine room. Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion in the ammonia sensors in the east engine room were nonfunctioning.  Instance B  On or about January 4, 2024, the employer did not perform inspections and testing for the dual safety pressure relief valves installed on the oil separators of the screw compressors. Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion, in that the pressure relief valves of compressors in the west and east engine room were beyond their tagged replace by dates.  Instance C  On or about January 4, 2024, the employer did not perform inspections and testing for emergency shutdown buttons associated with the ventilation systems of the east and west engine rooms.  Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion, in that the emergency shutdown buttons on the east engine room were not operational.  Instance D  On or about January 4, 2024, the employer did not perform inspections and testing of pressure vessels and piping associated with the ammonia refrigeration systems. Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion, in that equipment such as but not limited to, the high stage accumulator located in the west engine room and the associated piping showed evidence of deterioration of insulation and surface pitting.

Issued

Jun 17, 2024

Abate by

Feb 3, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information on paragraph (d) of this section) in a safe and timely manner when necessary means where taken to assure safe operation:   HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;  Instance A  On or about January 4, 2024, the employer did not ensure that the emergency shut down controls for the east engine room were functional, limiting the ability for employees to control ventilation of the room in the event of a release. Employees were exposed to hazards associated with anhydrous ammonia refrigeration systems such as, but not limited to, corrosive burns, eye damage, fire, and explosion.  Instance B  On or about January 4, 2024, the employer did not ensure that ammonia detection sensors in the engine rooms were functional, limiting the ability for employees to be warned of an ammonia release. Employees were exposed to hazards associated with anhydrous ammonia refrigeration systems such as, but not limited to, corrosive burns, eye damage, fire, and explosion.

Issued

Jun 17, 2024

Abate by

Feb 3, 2025

Penalty

Initial $16,131 · Current $8,678 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:  HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;  On or about January 4, 2024, the employer did not establish and implement all elements of an emergency action plan outlining the procedures for reporting a fire or other emergency such as an ammonia leak, procedures for emergency evacuation, and procedures to account for all employees, Employees were exposed to hazards associated with emergencies such as, but not limited to, fire and explosions resulting from a release of anhydrous ammonia.

Issued

Jun 17, 2024

Abate by

Feb 3, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(h)(2)(iii):The employer did not explain the applicable provisions of the emergency action plan to contract employers who work on or adjacent to a covered process:  HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;  On or about January 4, 2024, the employer did not ensure contract employers were provided an explanation of applicable provisions of the company's emergency action plan. Contract employees performing repair and maintenance activities on ammonia refrigeration systems were exposed to hazards associated with emergencies associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion.

Issued

Jun 17, 2024

Abate by

Feb 3, 2025

Penalty

Initial $16,131 · Current $8,678 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(o)(1):The employer did not certify that they have evaluated compliance with the provisions of this section at least every three years:  HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;  On or about January 4, 2024, the employer did not certify that they evaluated compliance with 29 CFR 1910.119 at least once every three years to verify that the procedures and practices developed under the standard are adequate and being followed. A PSM compliance audit should have been performed in 2020.  Employees were exposed to hazards associated with anhydrous ammonia such as, but not limited to, corrosive burns, eye damage, fire, and explosion in that deficiencies were identified in the company's PSM program.

Issued

Jun 17, 2024

Abate by

Feb 3, 2025

Penalty

Initial $16,131 · Current $8,678 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR  1910.151(c):Where employees were exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use:  HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;  Instance A  On or about March 19, 2024, the employer did not ensure employees were provided with suitable facilities for quick drenching or flushing of the eyes and body when exposed to corrosive materials. Employees working in the east engine room were exposed to hazards associated with anhydrous ammonia such as but not limited to irritation, corrosive burns, blister formation, permanent eye damage, and blindness. When actuating the emergency eyewash, the left eye cover did not open, and orange-brown discolored water came out of the shower head.  Instance B  On or about January 4, 2024, the employer did not ensure employees were provided with suitable facilities for quick drenching or flushing of the eyes and body on the outside of the west and east engine rooms when exposed to corrosive hazards associated with anhydrous ammonia, such as but not limited to irritation, corrosive burns, blister formation, permanent eye damage, and blindness.  Abatement Note:    ANSI/IIAR 9-2020 Standard for Minimum System Safety Requirements for Existing Closed Circuit Ammonia Refrigeration Systems.  7.3.7 General. Each machinery room shall have access to a minimum of two eyewash/safety shower units, one located inside the machinery room and one located outside of the machinery room, each meeting the requirements in Section 7.3.7.3. Additional eyewash/safety shower units shall be installed such that the path of travel in the machinery room is not more than 55 feet to an eyewash/shower unit.

Issued

Jun 17, 2024

Abate by

Jul 19, 2024

Penalty

Initial $16,131 · Current $8,678 Reduced

Hazardous substances 01702260

General-duty citation text

29 CFR  1910.1200(e)(1):Employer had not developed or implemented a written hazard communication program which a included the requirements outlined in 29 CFR 1910.1200(e)(1)(i) and (e)(1)(ii):   HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;  On or about January 4, 2024, the employer did not develop and implement the elements of a written hazards communication program for employees exposed to hazards chemicals such as, but not limited to, anhydrous ammonia, tetrasodium EDTA, and sodium hydroxide. Employees working near and around the ammonia refrigeration systems and engaging in sanitation operations were exposed to hazards associated with identified chemicals such as, but not limited to, severe irritation and or burns of the nose, throat, and respiratory tract, dyspnea, and severe eye damage including blindness.

Issued

May 15, 2024

Abate by

Feb 3, 2025

Penalty

Initial $16,131 · Current $8,678 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(f)(4):The employer did not develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel:  HK Cooperative, Inc. DBA J.H. Routh Packing Company located at 4413 Bogart Road in Sandusky, Ohio;   Instance A  On or about December 16, 2023, the employer did not develop and implement safe working practices to provide for the control of hazards during operations performed by contractors such as, but not limited to, lockout tagout.  The employer did not ensure contractors followed safe work practices by implementing lock out tag out procedures as outlined in 29 CFR 1910.147 to control the electrical, pressure, and chemical energy sources when replacing the Park RS solenoid valve coil on the Frick RXF-85-H High Stage Compressor (5A) located in the west engine room. Employees were exposed to hazards associated with liquid ammonia including, irritation to the eyes, nose, and throat, chest pain, skin burns, and frost bite.    Instance B  On or about December 16, 2023, the employer did not develop and implement safe working practices to provide for the control of hazards during operations performed by contractors such as, but not limited to, opening ammonia refrigeration piping and equipment.   The employer did not ensure contractors followed line break procedure guidelines to ensure the safe entry and repair to the Park RS solenoid valve coil on the Frick RXF-85-H High Stage Compressor (5A) located in the west engine room. Employees were exposed to hazards associated with liquid ammonia including, irritation to the eyes, nose, and throat, chest pain, skin burns, and frost bite.  Instance C  On or about December 16, 2023, the employer did not develop and implement safe working practices to provide for the control of hazards during operations performed by contractors such as, but not limited to, draining and off gassing ammonia-saturated oil from compressors. The employer did not ensure contractors followed safe working practices to ensure the safe repair of the Park RS solenoid valve coil on the Frick RXF-85-H High Stage Compressor (5A) located in the west engine room. Employees were exposed to hazards associated with liquid ammonia including, irritation to the eyes, nose, and throat, chest pain, skin burns, and frost bite.