Here’s a summary of two recent collections of proposed fines from OSHA. I’m not in any way affiliated with either of these facilities; I was just fortunate enough to get copies of the citations. There are plenty of things in this list to check on in your own facilities so I want to pass them on to you; it’s rare that we get to look at these without being the target! Ideally OSHA would make proposed fines public so EVERYONE could improve their compliance.
You’re going to see a lot of things that are painfully obvious to the seasoned PSM/RMP practitioner. I would like you to take notice how many of the high value fines fall into these two categories:
Not following through on observations of deficiencies: Whether they are observed in a walk-through or recorded as a suggestion on a mechanical integrity, PHA or PSM audit, you MUST follow up and correct these issues. A list of deficiencies from your audits is a goldmine for compliance officers; you’ve already done much of their work for them!
Calibrate instruments you rely on for process safety: Gauges, pressure transducers, thermometers – whatever instruments you rely on for process safety have to be regularly calibrated. You are relying on the data these instruments provide and it needs to be accurate. An example: Most facilities outsource their vibration analysis. That’s fine – but you need to qualify those contractors to ensure they are capable of performing the job including requiring calibration certificates from them. If you do vibration analysis in house you need to document the training of your technicians and ensure calibration based on the manufacturer’s recommendations. My understanding is that, since the vibration equipment wasn’t calibrated, all the tests that were conducted were voided in the Seafood Processing Facility.
First we have a Seafood processing facility and then a Cold Storage.
Region #1 – New Hampshire – Seafood Processor
$2,000 (SERIOUS) Ladder rung obstructed: Clearance behind a ladder rung. OSHA requires 7” of clearance. The ladder provided access to an evaporative condenser. Where the ladder and the condenser platform met there was a pipe running between the ladder and the condenser limiting clearance to 4”.
$7,000 (SERIOUS) Process Safety Information missing:
- No information on pipe specifications or minimum acceptable thickness.
- No U1A reports for five vessels.
- No vibration analysis
- No information on thermometers and gauges
$7,000 (SERIOUS) The employer did not document that the equipment in the process complied with recognized and generally accepted good engineering practices:
- Lines not properly labeled
- Pipe color did not match the color specified for service. (The company had specified all high pressure ammonia liquid lines were orange and a portion of a line was painted red during touch-up)
- Where ammonia lines passed through walls, the penetrations were not tightly sealed as required.
- Ice buildup on insulated portions of compressors and pumps.
- Ice buildup on insulated lines in cold storage areas.
- Condenser relief valves released at a working platform.
- Relief valves for receiver did not release 15’ above the adjacent grade.
- Compressor room exit door partially blocked.
- King valve not accessible without portable ladder.
$2,500 (SERIOUS) Written procedures for vibration analysis did not exist
$7,000 (SERIOUS) Inspections and tests were not performed on equipment to maintain its mechanical integrity:
- Vibration testing was not conducted on reciprocating compressors
- Autopurger not inspected for excess vibration.
- Vessel thicknesses not checked.
- Piping under compromised insulation not inspected.
$2,500 (SERIOUS) Mechanical Integrity of Control Valves: “Each ammonia shut-off valve was not cycled at least once every six months.”
$7,000 (SERIOUS) Items identified in mechanical integrity inspections were not addressed:
- Ice buildup on insulated portions of compressors and pumps.
- Ice buildup on insulated lines in cold storage areas.
- No U1A reports for five vessels.
- Torn insulation on a compressor
- Unidentified ammonia piping
$7,000 (SERIOUS) Employer did not certify 3 year PSM audits.
$70,000 (WILLFULL) Piping inspections did not occur where observation showed evidence of failure or breakdown of insulation.
$70,000 (WILLFULL) Ice formations had been noticed in 1997 audit and not completed as of December 2009. Items observed in April 2008 mechanical integrity inspection were not completed as of December 2009.
- Pipes marked as “severely rusted and pitted”
- Pipes marked as “not within acceptable limits”
- Pipes marked as “rusty” or “extensive corrosion”
- Relief valves on condensers were directed towards the workways.
$25,000 (REPEAT) A device used for vibration analysis was not calibrated as required.
Region #10 – Idaho – Cold Storage
$2,500 (SERIOUS) Exit door in compressor room not clearly visible in normal light and during a power outage and marked “Exit”.
$7,000 (SERIOUS) Intercom system used as alarm system did not have a battery backup and would not function during a power outage.
$7,000 (SERIOUS) The employer did not document that the equipment in the process complied with recognized and generally accepted good engineering practices:
- Ammonia Compressor Room – Emergency remote ventilation controls are not located outside the compressor room.
- Where ammonia lines passed through walls, the penetrations were not tightly sealed as required.
- Pipe labeling inadequate.
- High pressure receiver located in enclosed separate structure without ventilation.
$7,000 (SERIOUS) The Process Hazard Analysis must address the engineering and administrative controls applicable to the hazards and their interrelationship.
- High Pressure Receiver safety relief valve discharge is 2’ above roof level and 8’above adjacent ground exposing employees to potential exposure.
- Evaporator safety relief valve discharge is 2’ horizontally and 3’ vertically from the ladder to a platform exposing employees to potential exposure.
- Oil Pot safety relief valve discharge is 4’ from the platform exposing employees to potential exposure.
- Low Pressure Receivers are not protected from forklift traffic
$7,000 (SERIOUS) The employer must establish a system to ensure the Process Hazard Analysis team’s recommendations are resolved in a timely manner. A 2008 PHA states that mechanical ventilation in the compressor room is inadequate. The target completion date was April 2009 and still requires implementation.
$7,000 (SERIOUS) Inspections and tests were not performed on equipment to maintain its mechanical integrity: 57 pressure relief valves in use beyond their five year service life.
$2,500 (SERIOUS) Respirators: Respirators with canisters that list expiration date of 2004.
$2,500 (SERIOUS) Horizontal shafting must be protected by stationary casing: 3 rotary compressors lack guards.
$12,500 (REPEAT) Open sided platforms 4’ or more above adjacent ground must be guarded by standard railings or the equivalent.
$35,000 (REPEAT) The facility lacked a complete set of Piping and Instrumentation Diagrams (P&IDs).
$35,000 (REPEAT) Mechanical Integrity Procedures not established:
- For insulated and uninsulated anhydrous ammonia pipes. For vessels and heat exchangers. Specifically check for wall thickness.
- For ammonia pumps to be inspected annually
- For pressure gauges to be calibrated annually
- For temperature gauges to be calibrated annually
$35,000 (REPEAT) Electrical Equipment: Since ventilation is inadequate, the equipment located in the engine room and high pressure receiver enclosure must be intrinsically safe.
Does any of this look familiar to you?
