OSHA has cited a facility that produces retail frozen pizzas, retail dressings and sauces, and food service dressings and sauces with 27 health and safety violations, including two repeat, for inadequate hazardous energy control procedures after an August 2012 inspection at the company's facility was opened under OSHA's Site Specific Targeting Program for industries with high injury and illness rates. Proposed fines total $228,900.  Because of the hazards and the violations cited, the company has been placed in OSHA's Severe Violator Enforcement Program.  The two repeat violations were cited for failing to control hazardous energy, including conducting periodic inspections of energy control procedures and providing required information on written energy control procedures, such as specific rules and techniques, as well as testing requirements to determine the effectiveness of the energy control procedures. A total of 24 serious safety and health violations were cited for failing to guard machines, monitor noise exposure levels, train workers on emergency response and hazardous chemicals, provide permit confined space requirements and provide lockout/tagout procedures for the control of hazardous energy. Violations were also cited for OSHA's process safety management standard, including failing to document inspections, tests and system designs.  An other-than-serious violation was cited for failing to annually certify process safety management standard operating procedures. Here is a breakdown of the citations...

 

Fixed Stairs

  • 1910.24(b) - fixed industrial stairs were not provided for access to the roof for daily inspections and routine maintenance of ammonia refrigeration equipment (See my 2012 article discussing access/egress from rooftop refrigeration equipment); Serious; $7K

Process Safety Information

  • 1910.119(d)(3)(i)(D) - no relief system design and design basis for the ammonia refrigeration system in regards to the header and vent lines, oil pots, and HPR and LPR. Serious; $5,500
  • 1910.119(d)(3)(i)(E) - no ventilation design basis for two (2) engine rooms. Serious; $5,500
  • 1910.119(d)(3)(ii) - no documentation that the equipment complies with RAGAGEP(s): 1) a PSV from engine room #2 discharged at a working platform on a condenser, 2) PSVs were not replaced every five (5) years, nor was there an alternative replacement frequency based on in-service RV life. Serious; $5,500

Process Hazards Analysis

  • 1910.119(e)(5) - no system established to promptly address recommendations from a 2009 PHA which included: 1) develop policy/procedure for addressing RVs every five (5) years, 2) developing a policy/procedure for documentation of PM inspections/tests, 3) ensure RVs are relieving to safe locations, 4) address additional roof access and egress. Serious; $5,500

Operating Procedures

  • 1910.119(f)(1)(i)(B) - No SOP for draining oil from oil pots. Serious; $5,500

Mechanical Integrity

  • 1910.119(j)(2) - No written MI procedures for: 1) inspection of uninsulated NH3 piping, 2) corrosion under insulation inspections for NH3 piping, 3) testing of all safety cutouts on the compressors, 4) interior inspection of reciprocating compressors. Serious; $5,500
  • 1910.119(j)(4)(iv) - No documentation for each inspection/test that had been performed on NH3 system including: 1) testing of high pressure cutouts on recip compressors, 2) testing of high temp cutouts on recip compressors, 3) annual interior inspection of recip compressors. Serious; $5,500

3-year Audits

  • 1910.119(o)(1) - no 3- year audit done. Serious; $5,500

Emergency Response

  • 1910.120(q)(2) - the ERP did not address a response to Nitrogen. Serious; $7K

PPE (Fall Protection)

  • 1910.132(a) - no fall protection for workers were 20' climbing the frame work while unjamming conveyors in spiral freezers. Serious; $7K

Permit Required Confined Spaces (Spiral Freezers)

  • 1910.146(c)(1) - No confined space evaluation on spiral freezers. Serious; $7K
  • 1910.146(c)(4) - No Confined Space entry procedures for the spiral freezers. Serious; $7K
  • 1910.146(d)(3)(iii) - no isolation procedures and practices necessary to isolate the spiral freezers from the Nitrogen system and mechanical hazards of the conveyor chains. Serious; $7K
  • 1910.146(d)(3)(iv) - No procedures for ventilation of Nitrogen inside the spiral freezers. Serious; $7K
  • 1910.146(d)(3)(vi) - No procedures to verify that conditions in the spiral freezers were acceptable for entry throughout the duration of an authorized entry. Serious; $0
  • 1910.146(d)(4)(i) - Employer did not maintain the hand-held oxygen meter properly and did not ensure that employees used the equipment properly when entering PRCS's. Serious; $0
  • 1910.146(d)(5) - Employer did not evaluate the atmosphere prior to and during entry into the spiral freezers when entry operations were conducted. Serious; $0
  • 1910.146(d)(4)(vii) - employer did not provide equipment for safe ingress or egress by entrants into spiral freezers. Serious; $5,500
  • 1910.146(d)(9) - no procedures for summoning rescue and emergency services for rescuing entrants from PRCSs, for providing necessary emergency services to rescued employees and for preventing unauthorized personnel from attempting rescue in spiral freezers. Serious; $7K
  • 1910.146(e)(1) - Entry permits were not issued for entry by sanitation and maintenance employees into the spiral freezers. Serious; $7K
  • 1910.146(g)(1) - no training for employees whose work required entry into spiral freezers. Serious; $7K

LOTO

  • 1910.147(d)(3) - employer did not operate all energy isolating devices needed to control the energy to equipment, specifically electrical circuit breakers for conveyor chains for two spiral freezers. Serious; $0
  • 1910.147(d)(4)(i) - LOTO devices were not affixed to each energy isolating device by authorized employees. Serious; $0
  • 1910.147(c)(4)(ii) - LOTO procedures did not contain: 1) specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy; 2) specific requirement for testing a machine or equipment to determine and verify the effectiveness of LOTO devices and other energy control measures. REPEAT; $38,500
  • 1910.147(c)(6)(i) - no periodic inspection of energy control procedures at least annually. REPEAT; $38,500
  • 1910.119(f)(3) - SOPs not annually certified. Other-than-Serious; $0

Fire Extinguishers

  • 1910.157(g)(4) - employees designated to use firefighting equipment as part of the EAP were not provided training in the use of appropriate equipment upon initial assignment and annually thereafter. Serious; $4,400

Machine Guarding

  • 1910.212(a)(1) - pepperoni slicer not guarded. Serious; $7K

HAZCOM

  • 1910.1200(h)(1) - no training on Nitrogen hazards. Serious; $7K

CLICK HERE to download the citations (pdf).

The current citations can be viewed at http://www.osha.gov/ooc/citations/Richelieu_Foods_Inc_622339_.0228_13.pdf

 
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