Text For Citation: 01 Item/Group: 004 Hazard:

29 CFR 1910.119(e)(5):The employer did not establish a system to promptly address the team's findings and recommendations; assure that the recommendations were resolved in a timely manner and that the resolution was documented; document what actions were to be taken; complete actions as soon as possible; develop a written schedule of when these actions were to be completed; communicate the actions to operating, maintenance and other employees whose work assignments were in the process and who may have been affected by the recommendations or actions: On or about March 1, 2022 and at times prior thereto at the Pioneer Frozen Foods facility in Duncanville, TX, the employer did not establish a system to promptly address and track findings and document the resolution of recommendations action items resulting from the PHAs that were performed when: (a) The employer had not documented the resolution of the action item to evaluate the emergency evacuation procedures that was initially identified as a potential hazard to workers during the 2018 PHA. The 2018 PHA states: There are no assigned responsibilities in the event of an emergency situation. Inaction, confusion, or wrong actions results, increasing the exposure to hazardous consequences. An inadequate or obsolete evacuation procedure could cause employee overexposure to ammonia during an emergency situation involving ammonia release anywhere in the facility. (b) The employer had not documented the resolution of the action item to evaluate the emergency ventilation system and address potential hazards to workers that were initially identified during the 2018 PHA. The 2018 PHA states: Ventilation system not up to code for emergency situations, does not activate due to high levels of NH3 (NH3 detectors not interlocked with ventilation system). Failure to evaluate the emergency ventilation system could result in employee overexposure to ammonia during an emergency situation involving ammonia release in the engine room. (c) The employer had not documented the resolution of the action item to evaluate whether it would implement a HazMat team. The 2018 PHA states: Emergency equipment is incompatible between emergency response teams (e.g., fire department, hazardous response contractors, local emergency response teams, etc.). This results in an increased exposure to hazardous consequences. Inadequate response to an emergency situation involving ammonia release could cause employee overexposure to ammonia. (d) The employer had not documented its resolution of the action item to evaluate ammonia detection system and number of ammonia sensors for the process. The 2018 PHA states: If there are not sufficient ammonia detectors at the facility an ammonia release may not be detected. Failure to evaluate the ammonia detection system and number of ammonia sensors could cause employee overexposure to ammonia during an emergency situation involving ammonia release anywhere in the facility. (e) The employer had not documented its resolution of the action item to evaluate failure of its SCADA system which was identified as a potentially hazardous condition during PHA of the process. The 2018 PHA states that if a computer-control system fails, control of the refrigeration system is lost, NH3 liquid is isolated between two valves, overpressure develops, causing a leak/rupture and resulting in an NH3 release. Failure to evaluate SCADA system errors could cause employee overexposure to ammonia during an emergency situation involving ammonia release anywhere in the facility. (f) The employer had not documented its resolution of the action item to evaluate its need to replace the Purger which was identified as deficient and potentially hazardous to workers during PHA of the process. The 2018 PHA recommends replacement of the Purger due to age of the equipment. Failure to replace the Purger could cause employee overexposure to ammonia during an emergency situation involving ammonia release from this equipment. (g) The employer had not documented its resolution of the action item to evaluate eyewash requirements which was identified as need to address potential hazard during PHA of the process. The 2018 PHA states: Per IIAR Bulletin 109 and ANSI/IIAR-2 an emergency eye wash station and deluge body shower shall be located just outside the machine room exit door. An additional emergency eyewash station and deluge body shower should be readily accessible inside the machinery room. Failure to evaluate eyewash requirements could cause employee overexposure to ammonia during an emergency situation involving ammonia release in or near the engine room.