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

29 CFR 1910.119(e)(5):The employer did not complete actions to resolve PHA recommendations as soon as possible. a. On or about 14 December 2021, the employer failed to develop a tracking system for resolving PHA audit findings in a timely manner and could not show documentation that any PHA findings had been resolved, employees were exposed to a release of ammonia. 1. The 2016 and 2021 PHA System 1 subsystem 2, item 8. Proper PPE is not used when ammonia is added to the system? Recommendation: Revise and updated Standard operating procedures to include personal protection equipment (PPE) requirements and possible escape respirators was not resolved in a timely manner and is an ongoing hazard, failure to document and resolve PHA 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. The 2016 and 2021 PHA System 1 subsystem 2, item 26. There is excessive pressure in the system due to a fire? Recommendation: Consider Installation of a sprinkler system in the compressor room, was not resolved in a timely manner and is an ongoing hazard, failure to document and resolve PHA 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. The 2016 and 2021 PHA System 1 subsystem 4, item 2. A hand valve is left open or closed without periodic cycling? Recommendation: Consult manufacturer recommendation for frequency of valve cycling, was not resolved in a timely manner and is an ongoing hazard, failure to document and resolve PHA 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. The 2016 and 2021 PHA System 1 subsystem 4, item 18. There is only one means of egress from the roof in case of an ammonia release? Recommendation: Evaluate egress from roof to ensure it is adequate in an emergency, this recommendation was not resolved and the hazard is still present as their are areas with obstructed egress, failure to document and resolve PHA 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. The 2016 and 2021 PHA System 1 subsystem 4, item 19. There is inadequate means to contain an ammonia sill in the engine room? Recommendation: Consider staging covers at the floor drains located in the compressor room to prevent access in the event of a spill, was not resolved in a timely manner and is an ongoing hazard, failure to document and resolve PHA 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. The 2016 and 2021 PHA System 1 subsystem 4, item 20. The is inadequate means to contain an ammonia spill on the roof? Recommendation: Consider installing containments in significant areas of the roof, this recommendation was not resolved and the hazard is still present, failure to document and resolve PHA 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. The 2016 and 2021 PHA System 1 subsystem 4, item 22. There is inadequate training for operators? Recommendation: Develop a method to periodically check operator knowledge of standard operating procedures, this recommendation was not resolved and the hazard is still present, failure to document and resolve PHA findings in a timely manner exposed employees to potential exposure to anhydrous ammonia hazards such as but not limited to fire, asphyxiation or death. 8. The 2016 and 2021 PHA System 1 subsystem 6, item 13. There is too much ammonia in the recirculator? Recommendation: Consider implementing a monthly high level cut off test, this recommendation was not resolved and the hazard is still present, failure to document and resolve PHA findings in a timely manner exposed employees to potential exposure to anhydrous ammonia hazards such as but not limited to fire, asphyxiation or death. 9. The 2016 and 2021 PHA System 1 subsystem 6, item 13. High level alarm fails? Recommendation: Consider implementing a monthly high level cut off test, this recommendation was not resolved and the hazard is still present, failure to document and resolve PHA findings in a timely manner exposed employees to potential exposure to anhydrous ammonia hazards such as but not limited to fire, asphyxiation or death. 10. The 2016 and 2021 PHA System 1 subsystem 12, item 8. Emergency fan does not operate due to constant use for heat dissipation? Recommendation: Consider updates to the ventilation fan to ensure it is able to cool room during summer months, failure to document and resolve PHA findings in a timely manner exposed employees to potential exposure to anhydrous ammonia hazards such as but not limited to fire, asphyxiation or death. 11. The 2016 and 2021 PHA System 1 subsystem 18, item 4. Plate chiller is struck by a forklift or other object? Recommendation: Evaluate the use of equipment in areas containing the plate chillers to prevent accidental contact, this recommendation was not resolved and the hazard is still present, failure to document and resolve PHA 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.