Text For Citation: 01 Item/Group: 002B Hazard:

29 CFR 1910.119(e)(3)(iv): The process hazard analysis did not address the consequences of the failure of engineering and administrative controls: Employees engaged in production activities throughout the facility were exposed to chemical hazards associated with the catastrophic release of Ammonia in that the employer did not verify that the engine room complied with recognized and generally accepted good engineering practices such as IIAR Bulletin #111 06/02; ANSI/ISA; S91.01-1995; ANSI/ASHRE-15 2007; ANSI/IIAR 2-2008. The consequences of failure of engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases were not implemented to assure that the system operating modes are working at all times, the systems will reliably function when the need arises, and how to address in case the system is not properly working. a) Inspection, testing, and calibrating the controls was not conducted in 2012 for the Honeywell E/C-P2 Smart Cell - Ammonia Smart Sensor Module; and in 2014, 2015 for the GasGuard NH3 Ammonia Sensor. b) The GasGuard NH3 Ammonia Sensor in the Baked-Plant Engine Room was mounted at 7 feet 6 inches while the Manufacture Operating and Installation Manual states for optimum personnel protection mount the sensor at a height in the breathing zone of the employees and within 30 feet of potential leak sources. c) There is only one ammonia detector installed in the engine room to accommodate for the emergency ventilation control and for machinery room electrical shutdown while it was suggested that at least two detectors/sensors must be installed. 29 CFR 1903.19(d)(1) requires certification and documentation that the abatement of the above violation is completed.