OSHA Inspection: ADVANCEPIERRE FOODS, INC.

Issued

May 8, 2025

Abate by

Oct 31, 2025

Penalty

Initial $13,005 · Current $13,005

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(e)(1):The employer shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. Employers shall determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process.  a.) As of and prior to November 21, 2024, the employer's process hazard analysis (PHA) was not appropriate to the complexity of the process and did not identify, evaluate, and control the hazards involved in the 3 ammonia refrigeration systems of mechanical room #1.  The 2017 PHA and 2021 PHA Revalidation only addressed generic equipment in a generic ammonia refrigeration process, such as compressors, evaporators, pressure vessels, condensers and instruments and this generic approach did not identify, evaluate, and control the hazards from variations in equipment design, safe upper and lower operating and design limits, and operating and maintenance procedures for the types of equipment involved in the mechanical room #1 covered process. Due to the continued operation of a process which has not appropriately identified, evaluated, and controlled the hazards of the process by a PHA, employees have increased risk for exposure to ammonia released from the system(s) leading to corrosive injuries, burns or struck by injuries from fires and explosions, or death.  b.) As of and prior to November 21, 2024, the employer's process hazard analysis (PHA) was not appropriate to the complexity of the process and did not identify, evaluate, and control the hazards involved in the 3 ammonia refrigeration systems of mechanical room #1.  The 2017 PHA and 2021 PHA Revalidation only addressed a generic process with generic engineering and administrative controls applicable to the hazards, such as  procedures, mechanical integrity activities, training and safety switches, which did not allow for the employer to determine if the hazards are appropriately controlled and analyze the listed controls for the consequences of failure of those engineering and administrative controls which result from variations in equipment design, safe upper and lower operating and design limits, and operating and maintenance procedures for the types of equipment and controls involved in the mechanical room #1 covered process. Due to the continued operation of a process which has not appropriately identified, evaluated, and controlled the hazards of the process by a PHA, employees have increased risk for exposure to ammonia released from the system(s) leading to corrosive injuries, burns or struck by injuries from fires and explosions, or death.

Issued

May 8, 2025

Abate by

Oct 31, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(e)(3)(iii): The process hazard analysis did not address: Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases.  a.) As of and prior to November 21, 2024, the employer's process hazard analysis (PHA) did not address the specific controls applicable to system components and the interrelationships with the individual control to the hazards involved in the 3 ammonia refrigeration systems of mechanical room #1.  The 2017 PHA and 2021 PHA Revalidation only addressed generic engineering and administrative controls applicable to the hazards, such as  procedures, mechanical integrity activities, training and safety switches, which did not allow for the employer to determine if the hazards are appropriately controlled and analyze the listed controls for the consequences of failure of those engineering and administrative controls which result from variations in equipment design, safe upper and lower operating and design limits, and operating and maintenance procedures for the multiple types of equipment and controls involved in the mechanical room #1 covered process. Due to the continued operation of a process which has not appropriately identified, evaluated, and controlled the hazards of the process by a PHA, employees have increased risk for exposure to ammonia released from the system(s) leading to corrosive injuries, burns or struck by injuries from fires and explosions, or death.

Issued

May 8, 2025

Abate by

Oct 31, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(e)(3)(iv): The process hazard analysis did not address: Consequences of failure of engineering and administrative controls;  a.) As of and prior to November 21, 2024, the employer's process hazard analysis (PHA) did not address the consequences of failure for the specific controls applicable to system components for hazard(s) control involved in the 3 ammonia refrigeration systems of mechanical room #1. The PHA report did not list individual or specific controls for the PHA team to address consequences of failure in the analysis. The 2017 PHA and 2021 PHA Revalidation only addressed generic engineering and administrative controls applicable to the hazards, such as  procedures, mechanical integrity activities, training and safety switches, which did not allow the employer to analyze the listed controls for the consequences of failure of those engineering and administrative controls which result from variations in equipment design, safe upper and lower operating and design limits, and operating and maintenance procedures for the multiple types of equipment and controls involved in the mechanical room #1 covered process. Due to the continued operation of a process which has not appropriately identified, evaluated, and controlled the hazards of the process by a PHA, employees have increased risk for exposure to ammonia released from the system(s) leading to corrosive injuries, burns or struck by injuries from fires and explosions, or death.

Issued

May 8, 2025

Abate by

Oct 31, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(e)(4): The process hazard analysis shall be performed by a team with expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used.  a.) As of and prior to November 21, 2024, the employer's process hazard analysis for the 2021 PHA revalidation was not performed by a team and was only performed by the Senior PSM Area Manager. The PHA revalidation did not include any documentation for team members, other than the Senior PSM Manager, and did not include a team member with operating experience and knowledge specific to the Mechanical Room #1 ammonia refrigeration systems as required by this part, such as a roundsman, refrigeration technician or powerhouse operator (as noted by internal policy for team members).

Issued

May 8, 2025

Penalty

Initial $7,802 · Current $1,000 Reduced

General-duty citation text

29 CFR  1910.1200(f)(6)(ii): Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.   a.) On or about November 22, 2024, the employer did not ensure a 55-gallon drum in Engine Room #1 containing US Petrolon Industrial, Inc USPI 1009-68S (Reproductive toxicity) included words, pictures, or symbols, or combination thereof to provide general information about the physical and health hazards of the chemical.