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

29 CFR 1910.119(e)(5): The employer did not establish a system to assure that the recommendations are resolved in a timely manner ; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; and communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions: Hanover Foods Corporation, Clayton, Delaware (with respect to ammonia refrigeration processes): On or about 10-1-2022, the employer's established system, with respect to the 2018 Process Hazard Analysis (PHA), did not assure for the timely resolutions to recommendations and the completion of actions as soon as possible, nor develop a written schedule of when actions are to be completed for the following PHA items, exposing employees to fire and chemical overexposure hazards posed by anhydrous ammonia in the event of an uncontrolled release. (a) PHA No. 1.19: RECOMMENDATION(S) - Consider updating Mechanical Integrity program to call out replacing relief valves that have opened. DETERMINED ACTION(S) - Procedure will need developed and added to MI Program. This is an ongoing hazardous condition that can result in the release of ammonia casuing serious injury to employees. (b) PHA No. 1.23: RECOMMENDATION(S) - Consider replacing Micro panels in System #4 to replace obsolete equipment to allow safe starting of compressor. DETERMINED ACTION(S) - Need to gather more information on recommendation. This is an ongoing hazardous condition that can result in possible damage to a compressor with a subsequent ammonia release into the engine room causing serious injury to employees. (c) PHA No. 1.25: RECOMMENDATION(S) - Install proper relief protection piped back to the oil separator. DETERMINED ACTION(S) - Need to gather more information on recommendation. This is an ongoing hazardous condition that can result in the release of ammonia causing serious injury to employees. (d) PHA No. 3.04: RECOMMENDATION(S) - Consider documented training for operators on manual defrost. DETERMINED ACTION(S) - SOP needs to be created and training done to ensure operators understand the manual defrost process. This is an ongoing hazardous condition that can result in the release of ammonia casuing serious injury to employees. (e) PHA No. 3.06: RECOMMENDATION(S) - Create Preventative Maintenance for high level cut out testing and verification of proper compressor shutdown. DETERMINED ACTION(S) - PM needs created in CMNS to frequency, refrigeration contractor will complete testing. This is an ongoing hazardous condition that can result in possible damage to a compressor with a subsequent ammonia release into the engine room causing serious injury to employees. (f) PHA No. 3.15: RECOMMENDATION(S) - Review SOP to ensure oil draining process is covered for oil pots. DETERMINED ACTION(S) - SOP's will be reviewed and updated accordingly. (g) PHA No. 3.3: RECOMMENDATION(S) - Consider adding mechanical low level cut out for pumps to CS-2, Frigo, Flume and D recirculators. DETERMINED ACTION(S) - Need to gather additional information pertaining to recommendation. This is an ongoing hazardous condition that can result in the release of ammonia causing serious injury to employees. (h) PHA No. 4.07: RECOMMENDATION(S) - Evaluate pump discharge check valve and isolation valve arrangement for proper protection. DETERMINED ACTION(S) - Need to gather more information on recommendation. This is an ongoing hazardous condition that can result in damage to a pump and loss of seal and a subsequent release of ammonia causing serious injury to employees. (I) PHA No. 4.09: RECOMMENDATION(S) - Add pump discharge reading to shift round sheet. DETERMINED ACTION(S) - Will need to review current log sheet to see if pressure is being documented. (j) PHA No. 5.01: RECOMMENDATION(S) - Update shift round sheet to inspect heat exchangers. DETERMINED ACTION(S) - Need to review current log sheet to see if information was added. (k) PHA No. 6.1: RECOMMENDATION(S) - Investigate protecting units from being struck by forklift. DETERMINED ACTION(S) - Need to gather more information on recommendation. (l) PHA No. 6.24: RECOMMENDATION(S) - Training for refrigeration Operators to do defrost. Consider upgrading to hot gas defrost evaporators. DETERMINED ACTION(S) - SOP needs to be created and training done to ensure operators understand the manual defrost process. Need to get quotes for upgrading evaporators to hot gas defrost. This is an ongoing hazardous condition that can result in a tube leak or ruptures due to high pressure or corrosion, with subsequent ammonia release from the evaporator system causing serious injury to employees. (m) PHA No. 7.03: RECOMMENDATION(S) - Investigate creating SOP to cover liquid transfer scenarios. DETERMINED ACTION(S) - SOP needs to be created. This is an ongoing hazardous condition that can result in no transfer, possible high level in the suction trap and compressor damage with a release of ammonia casuing serious injury to employees. (n) PHA No. 8.01: RECOMMENDATION(S) - Add purger inspection to daily shift rounds. DETERMINED ACTION(S) - Need to review current log sheet to see if information was added. This is an ongoing hazardous condition that can result in the release of ammonia causing serious injury to employees. (o) PHA No. 11.02: RECOMMENDATION(S) - Evaluate insulation on pipe and vessels and develop 5-year and then continues plan. Remove all Arma-Flex insulation from piping to prevent premature corrosion. DETERMINED ACTION(S) - Insulation repair list needs created. This is an ongoing hazardous condition that can result in the release of ammonia due to a pipe break causing serious injury to employees. (p) PHA No. 11.02: RECOMMENDATION(S) - Evaluate insulation on pipe and vessels and develop 5-year and then continues plan. Remove all Arma-Flex insulation from piping to prevent premature corrosion. DETERMINED ACTION(S) - System review needs done of areas that insulation needs removed and corrective actions after insulation is removed. This is an ongoing hazardous condition that can result in the release of ammonia due to a pipe break causing serious injury to employees. (q) PHA No. 12.01: RECOMMENDATION(S) - Evaluate rooftop access, consider evaluating condenser SOPs for emergency shut down at compressors. DETERMINED ACTION(S) - Condenser SOP's need reviewed for emergency shutdown at the compressors. (r) PHA No. 12.11: RECOMMENDATION(S) - Review Emergency Action Plan to determine if parts ERP is present, clearly define one or others. DETERMINED ACTION(S) - Complete program review needs done to ensure proper information is in place. (s) PHA No. 12.22: RECOMMENDATION(S) - Review exterior showers for availability and code requirement, Review rooftop eyewash DETERMINED ACTION(S) - Will evaluate areas for best placement for eyewash stations. This is an ongoing hazardous condition that can result in the increased severity of employee injury as rinsing of ammonia from the eyes or skin is delayed. Pursuant to 29 CFR 1903.19, the employer must submit 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.