Text For Citation: 01 Item/Group: 003A Hazard:

29 CFR 1910.119(o)(4):The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, and did not document that deficiencies had been corrected. a. Compliance Audit - On or about December 14, the employer had failed to promptly address and document the resolution of deficiencies found during the 2020 compliance audit, exposing employees to fire and chemical overexposure hazards posed by anhydrous ammonia in the event of an uncontrolled release of ammonia. 1. Audit finding 4.1 states, site should clearly indicate which procedures apply to each system and or if a procedures may not be used on a specific system, this was found to be an ongoing violation that the employer had not resolved, failure to document and resolve audit findings in a timely manner exposed employees to potential exposure to anhydrous ammonia hazards such as but not limited to fire, asphyxiation or death. 2. Audit finding 4.2 states, Develop required SOP's for Screw Compressors as they have a different shutdown procedure than the Vilter compressors, this was found to be an ongoing violation that the employer had not resolved, failure to document and resolve audit findings in a timely manner exposed employees to potential exposure to anhydrous ammonia hazards such as but not limited to fire, asphyxiation or death. 3. Audit finding 4.3. states, Ensure any future developed procedures contain specific information such as flow rates, pressures, operating limits and consequences of deviations with steps to correct or avoid the deviations. Update/Develop SOP'S as indicated in 4.1 and 4.2, this was found to be an ongoing violation that the employer had not resolved, failure to document and resolve audit findings in a timely manner exposed employees to potential exposure to anhydrous ammonia hazards such as but not limited to fire, asphyxiation or death. 4. Audit Finding 2.4 states, Update P&IDs to ensure that the new 150 ton system valves Ids are included as indicated (Sheet R-31 blank). Facility has not updated/maintained the PSM binder attachment with the P&ID's." Recommendations, Update P&IDs to ensure that the new 150 ton system valves Ids are included as indicated (Sheet R-31 blank)" "Update the P&ID attachment in the PSM binder with a current copy or update, these were found to be an ongoing violation that the employer had not resolved, failure to document and resolve audit findings in a timely manner exposed employees to potential exposure to anhydrous ammonia hazards such as but not limited to fire, asphyxiation or death. 5. Audit Finding 4.5 states, Include pertinent safety systems and their functions in the operating procedures. For example, facility should include information on how to diagnose each alarm, when it is acceptable to deactivate an alarm, actions to take for a malfunctioning alarm and logic of the interlock system. Detailed troubleshooting information is also recommended, including what is displayed on the screen, what steps to take, etc., this was found to be an ongoing violation that the employer had not resolved, failure to document and resolve audit findings in a timely manner exposed employees to potential exposure to anhydrous ammonia hazards such as but not limited to fire, asphyxiation or death. 6. Audit Finding 13.5 states, Develop a formal plan to complete all findings. Consider assigning work order numbers in the PCM system to track corrective action completions, this was found to be an ongoing violation that the employer had not resolved, failure to document and resolve audit findings in a timely manner exposed employees to potential exposure to anhydrous ammonia hazards such as but not limited to fire, asphyxiation or death. 7. Audit Finding 3.5 states, Ensure timely completion of PHA recommendations with appropriate documentation. Document sound reasoning if a recommendation is rejected. Assign each PCM work order a number to the corresponding PHA finding to be corrected as appropriate. This will facilitate validation for future PSM audits/PHA updates and improve tracking of corrective action closures, this was found to be an ongoing violation that the employer had not resolved, failure to document and resolve audit findings in a timely manner exposed employees to potential exposure to anhydrous ammonia hazards such as but not limited to fire, asphyxiation or death. Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.