Lack of emergency planning for ammonia leaks put workers at a beverage plant in harm’s way three (3) times in the past year. As a result, the Department of Labor & Industries (L&I) has fined the business $154,000 for multiple willful, serious and general workplace safety violations.  In each of the incidents, when the leaks occurred, employees were unsure what to do, which way to run to escape the corrosive vapors and how to call for emergency help.  In one situation last August, panicked employees ran downwind of the leak into the vapor cloud. Eight employees were exposed; one was sickened and taken to the hospital.  L&I has cited the company for two (2) willful violations, each with the maximum legal penalty of $70,000. The beverage business has also been cited for two serious violations with a $7,000 penalty, also the maximum.  

The first willful violation is for not developing a comprehensive written emergency response plan on what to do in the event of an ammonia leak. The plan should include information on communication, pre-emergency planning and drills.  After the disorganized response to the first leak in December 2015, the local fire department advised the company to call 9-1-1 sooner and to prepare a detailed employee emergency evacuation plan. However, months later there were two (2) more ammonia leaks, also with disorganized evacuations, poor communication and miscommunication with the fire department.

The second willful violation was cited for not providing employees with emergency response training that specifically addressed what to do during an ammonia leak. That citation was also for not designating and training specific employees to assist in a safe and orderly evacuation.  

One of the serious violations was for NOT providing an ammonia alarm system to alert employees when they need to evacuate the work area. The second serious violation was for NOT ensuring that voluntary use of respirators was done safely. 

Here is a breakdown of the citations:

Violation 1 Item 1a

Violation Type: Willful Serious; $70,000

WAC 296-824-20005(1)

The employer did not develop an emergency response plan that adequately addresses the minimum requirements to ensure employee safety from anhydrous ammonia emergencies. It must cover at a minimum pre-emergency planning, personnel roles and lines of authority and communications for all affected parties including responders, and employee training. The plan should include the required elements specific to ammonia. Employees worked in a facility that contained anhydrous ammonia. There were three ammonia leaks in less than a year. After the first leak the employer was instructed by local emergency responders to come up with a plan to address ammonia leaks. No adequate plan was produced. Months later there were two more leaks.

The employer's responses included disorganized evacuations, evacuations downwind of the leak, as well as poor communication, and miscommunication to local emergency responders. Exposure to anhydrous ammonia can lead to serious injury and/or death.

The following additional correction documentation is required for this violation: A copy of the emergency response plan specific to ammonia leaks, and/or updated accident prevention program containing the

A copy of the emergency response plan specific to ammonia leaks, and/or updated accident prevention program containing the the emergency response plan minimum requirements below, specific to ammonia leaks. It must contain at minimum:

  • Pre-emergency planning and coordination with additional responders (including personnel from other employers such as: Fire departments, law enforcement agencies, emergency medical services, and state or federal agencies)
  • Personnel roles, (See Table 1) and lines of authority and communications for all affected parties including responders
  • Employee training (see WAC 296-824-30005 for more detail).

Correct by: 4/3/2017

 

Violation 1 Item 1b

Violation Type: Willful Serious; GROUPED

WAC 296-24-567(1)(b)

The employer did not put an emergency action plan for anhydrous ammonia in writing. It must cover those designated actions employers and employees must take to ensure employee safety from fire and other emergencies. The plan should include the required elements specific to ammonia. Employees worked in a facility that contained anhydrous ammonia. There were three ammonia leaks in less than a year. After the first leak the employer was instructed by local emergency responders to come up with a plan to address response to ammonia leaks. No adequate plan was produced. Months later there were two more leaks. The employer's responses included disorganized evacuations, evacuations downwind of the leak, as well as poor communication, and miscommunication to local emergency responders. Exposure to anhydrous ammonia can lead to serious injury and/or death.

The violations above have been grouped because they involve similar or related hazards that may increase the potential for illness or injury resulting from an exposure or accident. A single penalty is applied to the first item in the group.

The following additional correction documentation is required for this violation:

A copy of the emergency action plan specific to ammonia leaks, and/or updated accident prevention program containing the emergency action plan minimum elements below, specific to ammonia leaks.

It must contain the following elements specific to an ammonia leak:

(i) Emergency escape procedures and emergency escape route assignments;

(ii) Procedures to be followed by employees who remain to operate critical plant operations before they evacuate;

(iii) Procedures to account for all employees after emergency evacuation has been completed;

(iv) Rescue and medical duties for those employees who are to perform them;

(v) The preferred means of reporting fires and other emergencies; and

(vi) Names or regular job titles of persons or departments who can be contacted for further information or explanation of duties under the plan.

 

Violation 1 Item 2a

Violation Type: Willful Serious; $70,000

WAC 296-824-30005

The employer did not provide initial training before an employee was allowed to participate in actual emergency response operations during an ammonia leak. Employees were not trained on emergency response procedures specific to an ammonia leak. Employees worked in a facility that contained anhydrous ammonia.There were three ammonia leaks in less than a year. After the first leak the employer was instructed by local emergency responders to come up with a plan to address response to ammonia leaks. No adequate plan was produced and no adequate training was given to employees. Months later there were two more leaks. The employer's responses included disorganized evacuations, evacuations downwind of the leak, as well as poor communication, and miscommunication to local emergency responders. Exposure to anhydrous ammonia can lead to serious injury and/or death.

Correct by: 4/3/2017 Violation 1 Item 2b

 

Violation 1 Item 2b

Violation Type: Willful Serious; GROUPED 

WAC 296-24-567(1)(e)(i)

The employer did not designate and train a sufficient number of persons to assist in the safe and orderly emergency evacuation of employees during an ammonia leak. Employees were not trained on evacuation procedures specific to an ammonia leak. Employees worked in a facility that contained anhydrous ammonia. There were three ammonia leaks in less than a year. After the first leak the employer was instructed by local emergency responders to come up with a plan to address response to ammonia leaks. No adequate plan was produced and no adequate training was given to employees. Months later there were two more leaks. The employer's responses included disorganized evacuations, evacuations downwind of the leak, as well as poor communication, and miscommunication to local emergency responders. Exposure to anhydrous ammonia can lead to serious injury and/or death.

The violations above have been grouped because they involve similar or related hazards that may increase the potential for illness or injury resulting from an exposure or accident. A single penalty is applied to the first item in the group.

Correct by: 4/3/2017

 

Violation 2 Item 1

Violation Type: Serious; $7,000

WAC 296-800-31070

The employer did not ensure there was an appropriate employee alarm system for anhydrous ammonia. Employees work in a facility that uses an anhydrous ammonia refrigeration system with an alarm system that is not distinct and recognizable to evacuate the work area. Lack of an appropriate alarm system can cause employees to not be aware of ammonia in the area which can cause serious injury and or death.

Correct by: 4/3/2017

 

Violation 2 Item 2

Violation Type: Serious; $7,000

WAC 296-842-11005(3)

The employer did not ensure that voluntary use of respirators was done safely. One employee was using a respirator without the proper training and provisions during an ammonia leak. Improper use of a respirator in a hazardous atmosphere can lead to serious injury and or death.

The following additional correction documentation is required for this violation:

If respirators will be used, a written respiratory protection program is required to be submitted for review.

Correct by: 4/3/2017

 

Violation 3 Item 1

Violation Type: General; $0.00

WAC 296-800-16010

The employer did not ensure to document the hazard assessment for PPE when the ammonia refrigeration system was installed. Employees work in a facility with anhydrous ammonia refrigeration system.

Correct by: 4/3/2017 

 

CLICK HERE (pdf) to download the citations

 
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