Text For Citation: 02 Item/Group: 001 Hazard:

29 CFR 1910.119(d): The employer did not complete a compilation of written process safety information, including information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process before conducting the process hazard analysis: a) On or about November 8, 2018, and at times prior thereto, the employer failed to have a maximum inventory of the quantity of anhydrous ammonia in the system. The refrigeration system contains approximately 16,500 pounds of anhydrous ammonia for refrigerant for the freezers and to cool the processing floor. The employer presented an intended inventory of 9,867 pounds. Employee(s) are exposed to the hazards associated with anhydrous ammonia such as asphyxiation, chemical burns, and fire. b) On or about November 8, 2018 and at times prior thereto, the employer failed to ensure piping and instrument diagrams (P&ID) were updated and correct. The P&ID's were not updated and did not show the isolation valves for the #2 compressor was taken off line. Employee(s) are exposed to the hazards associated with anhydrous ammonia such as asphyxiation, chemical burns, and fire. c) On or about November 8, 2018 and at times prior thereto, the employer failed to ensure they maintained a current listing and function for the pressure relief valves. The employer uses over 10,000 pounds of anhydrous ammonia for refrigerant for the freezers and to cool the processing floor. Employee(s) are exposed to the hazards associated with anhydrous ammonia such as asphyxiation, chemical burns and fire. d) On or about November 8, 2018, and at times prior thereto, the employer failed to ensure the anhydrous ammonia receiver (V0-1) was protected from being struck by vehicles and/or equipment in accordance with Recognized and Generally Good Engineering Practices (RAGAGEP), such as but not limited to, the guidance set forth in International Institute of Ammonia Refrigeration IIAR 2, 2014, Section 7.2.4. Employee(s) are exposed to an unexpected release of anhydrous ammonia. e) On or about November 8, 2018, and at times prior thereto, the employer failed to document the king valve was visibly labeled and was accessible in accordance with Recognized and Generally Accepted Good Engineering Practices (RAGAGEP), such as but not limited to, the guidance set forth International Institute of Ammonia Refrigeration IIAR Bulletin 109. Employee(s) are exposed to the delay of isolating the ammonia at the receiver in the event of an incident. f) On or about November 8, 2018, and at times prior thereto, the employer failed to document the machinery room as a hazardous (Classified) Location (of not less than a Class 1, Division 2) in accordance with Recognized and Generally Accepted Good Engineering Practices (RAGAGEP), such as but not limited to, IIAR 2, 2014, Section 6.8. The employer uses over 10,000 pounds of the anhydrous ammonia for refrigerant for the freezers and to cool the processing floor. Employee(s) are exposed to an unexpected release of anhydrous ammonia. g) On or about November 8, 2018, and at times prior thereto, the employer failed to document that there was a least one calibrated and operating anhydrous ammonia detector in the machinery room that would activate an alarm and mechanical ventilation in accordance with RAGAGEP, such as, but not limited to IIAR 2, 2014, Section 6.13 and 6.14 Standard for Safety Design of Closed?Circuit Ammonia Refrigeration Systems. Employee(s) are exposed to the hazards associated with anhydrous ammonia such as asphyxiation, chemical burns, and fire. h) On or about November 8, 2018, and at times prior thereto, the employer failed to document there were working visual and audible alarms inside the engine room and outside each entrance to the engine room in accordance with Recognized and Generally Accepted Good Engineering Practices (RAGAGEP), such as but not limited to, the guidance set forth in IIAR 2, 2014, Section 6.13 and Section 17. Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems. Employee(s) are exposed to the hazards associated with anhydrous ammonia such as asphyxiation, chemical burns, and fire. i) On or about November 8, 2018, and at times prior thereto, the employer failed to document that in the event of a release the system was being monitored with a continual oversight to a responsible party in accordance with Recognized and Generally Accepted Good Engineering Practices (RAGAGEP), such as but not limited to, the guidance set forth in IIAR 2, 2014, Section 17, Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems. Employee(s) are exposed to the hazards associated with anhydrous ammonia such as asphyxiation, chemical burns, and fire. j) On or about November 8, 2018, and at times prior thereto, the employer did not document that they complied with Recognized and Generally Good Engineering Practices (RAGAGEP), such as IIAR 2, 2014 ,Section 6.4, Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems, when the employer failed to ensure that flammable and combustible materials such as miscellaneous wood items were not stored in the machinery room. This condition exposed employee(s) to the hazards associated with anhydrous ammonia such as asphyxiation, chemical burns, and fire. k) On or about November 8, 2018, and at time prior thereto, the employer did not ensure material and energy balances were provided for the process. The employer uses over 10,000 pounds of the anhydrous ammonia for refrigerant for the freezers and to cool the processing floor. One onsite document stated the system contained about 12,788 pounds of anhydrous ammonia, the employer stated the system contained about 9,867 pounds of anhydrous ammonia. Employee(s) are exposed to the hazards associated with anhydrous ammonia such as asphyxiation, chemical burns, and fire. l) On or about November 8, 2018, and times prior thereto, the employer did not develop a process flow diagram for the process. The employer uses over 10,000 pounds of the anhydrous ammonia for refrigerant for the freezers and to cool the processing floor. Employee(s) are exposed to the hazards associated with anhydrous ammonia such as asphyxiation, chemical burns, and fire.