Text For Citation: 01 Item/Group: 007A Hazard:

29 CFR 1910.119(l)(1): The employer did not establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process: Employees engaged in production activities throughout the facility were exposed to chemical hazards associated with the catastrophic release of Ammonia in that the employer had not implemented the management of change program to address changes to the Ammonia process; there have been several changes to the processes such as but not limited to the following: a) MOC 2014-1, the employer submitted a document on 7-17-2014 for adding 2 of the 2" Hansen Globe Valves to Hot Gas Header Baked Plant, the document is incomplete in that the employer could not provide document to support that Standard Operating Procedures had been changed; the Process Safety Information such as P&IDs have been updated with the new valves on the drawings; and the Ammonia process employees (Refrigeration Specialists) have been trained. b) MOC 2014-2, the employer submitted a document on 2-06-2014 for replacing the Booster Compressor for more capacity (30hp - 58hp), the document is incomplete in that the employer did not fill out all the yes/no questions on the second section of the form. The employer could not provide document to support that the Process Safety Information have been updated; and the Refrigeration Specialists have been trained. c) MOC 2014-3, the employer submitted a document on 3-10-2014 for removing the flanges on liquid line and check valves to roof to reduce potential leaks inside plant, the document is incomplete in that the employer could not provide document to support that the Process Safety Information such as P&IDs have been updated with the removing items on the drawings; and the Refrigeration Specialists have been trained about the changes. d) MOC 2014-2, the employer submitted a document on 12-04-2014 for replacing the C-1 Compressor loader un-loader valve with different name brand (Vickers to Yuken), the document is incomplete in that the employer could not provide document to support that the Process Safety Information such as P&IDs have been updated with the replacing valves on the drawings; and the Refrigeration Specialists have been trained about the changes. e) The employer did not have any management of change (MOC) documentation for the stripping-off/removal of insulation, and the replacing the new piping in 2013. f) The employer did not have any management of change (MOC) documentation for the installation of the Ammonia Emergency Shut-Off button and the Exhaust Fan switch outside of the engine room. 29 CFR 1903.19(d)(1) requires certification and documentation that the abatement of the above violation is completed.