Details

Parent Category: Safety Info Posts

Category: PSM and RMP Citations/Analysis

Published: 20 November 2013

OSHA has cited a processor of chicken, beef and pork for repeat and serious violations of workplace safety standards following an inspection at a NY manufacturing plant. The proposed fines total of $121,720. The inspection, which began on May 15, was conducted under OSHA's Site Specific Targeting Program, which directs enforcement resources to high-hazard workplaces with the highest rates of injuries and illnesses. OSHA found a cross section of mechanical, electrical and fall hazards, as well as several deficiencies in the plant's process safety management program for its refrigeration system that uses ammonia. These conditions resulted in the issuance of 11 serious citations with $61,000 in fines and three repeat citations were issued with $60,720 in fines.  There are a couple of NOTABLE citations that should garner MUCH ATTENTION in the refrigeration industry:

1) RV discharge distance is measured by work platforms and NOT merely from the roof.  One of the REPEAT citations was associated with RV discharge not being over 15' above the condenser platforms.

2) SOP details MEAN A LOT... SOPs with incomplete sentences, referencing non-existing equipment and documents NOT associated with the plant.  Interviews with engineers and operators indicated no one knew what the SOPs were meant to say or what equipment they were referencing.

Folks - using another facility's SOPs is a STARTING POINT.  And although many traditional safety programs can be revised using the "Find and Replace" function within WORD; PSM operating procedures are NOT that easily adopted into a facility specific operating procedures.  It looks like OSHA is actually reading SOPs in their inspections!  Keep in mind, the inspector/auditor does not need to be an "expert" in your process to have the ability to identify incomplete sentences in the SOP or identify equipment that is not listed in the PSI.  And to top it off, when they ask the very workers who operate/maintain the process about these discrepancies and no one can explain them; we have just sunk our battleship!  Here is a breakdown of the citations:

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