OSHA Inspection: SIMMONS ANIMAL NUTRITION, INC.

Issued

2024-01-12 00:00:00

Penalty

Initial $12278.00 · Current $0.00 Reduced

Hazardous substances 01700175

General-duty citation text

29 CFR 1910.37(b)(5): Each doorway or passage along an exit access that could be mistaken for an exit was not marked "Not an Exit" or similar designation or identified by a sign indicating its actual use:  a) 8141 Seashore Highway, Bridgeville, DE (Access to the Engine Room): On or about July 17, 2023, the doorway or passage along an exit access had not marked a doorway, such as but not limited to, that leading into the engine room from the maintenance shop, "NOT AN EXIT" or a sign indicating its actual use, potentially exposing employees unknowingly choosing to egress through the engine room during an emergency involving the unexpected release of anhydrous ammonia in the engine room to health hazards posed by anhydrous ammonia.

Issued

2024-01-12 00:00:00

Abate by

2024-02-08 00:00:00

Penalty

Initial $15625.00 · Current $0.00 Reduced

Hazardous substances 01700175

General-duty citation text

29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices:  a) 8141 Seashore Highway, Bridgeville, DE (Engine Room, SE End of Facility): On or about July 17, 2023, employees were subject to an increased risk for severe injury due to both the potential fire and toxic chemical overexposure hazards posed by anhydrous ammonia under certain conditions as the employer did not document the equipment complies with Section 6.4 of ANSI/IIAR 2 - Standard for the Safe Design of Closed-Circuit Refrigeration Systems when the employer stored a pallet holding 55-gallon drums, containing combustible waste oil, in the engine room placed on the floor in front of a ventilation louver blocking both egress through an aisle and air flow through the louver. Insufficient air flow can result in excessive ammonia vapor accumulation in the engine room in the event of an ammonia release with subsequent employee overexposure to ammonia. Furthermore, the presence of this waste oil, a combustible material, within the engine room could augment a fire initiated by the ignition an ammonia vapor cloud within the engine room under the right conditions.  b) 8141 Seashore Highway, Bridgeville, DE (Engine Room, SE End of Facility): On or about July 17, 2023, employees were subject to an increased risk for severe injury due to both the potential fire and toxic chemical overexposure hazards posed by anhydrous ammonia under certain conditions as the employer did not document the equipment complies with Section 6.8.2 of ANSI/IIAR 2 - Standard for the Safe Design of Closed-Circuit Refrigeration Systems when the employer did not ensure the ventilation in the engine room met the requirements of IIAR 2-2014, Section 6.14.7 for emergency ventilation, and IIAR-2-2014, Section 6.13 for ammonia detection, for an engine room not classified as a Class I, Group D, Division 2 location. Following an accidental release of ammonia in the engine room ammonia vapor can accumulate in the air at ignitable concentrations exposing employees to a fire hazard.  c)  8141 Seashore Highway, Bridgeville, DE (Engine Room, SE End of Facility): On or about July 17, 2023, employees were subject to an increased risk for severe injury due to both the potential fire and toxic chemical overexposure hazards posed by anhydrous ammonia under certain conditions as the employer did not document the equipment complies with Section 6.10.2 of ANSI/IIAR 2 - Standard for the Safe Design of Closed-Circuit Refrigeration Systems when the employer did not ensure an engine room door, used as a means of egress, had panic hardware and swings in the direction of egress should employees exit from the engine room in the event of an emergency. Doors not having these features can delay an emergency evacuation from the engine room resulting in employee exposure potentially to both fire and chemical overexposure hazards posed by anhydrous ammonia in the engine room.  d)  8141 Seashore Highway, Bridgeville, DE (Engine Room, SE End of Facility): On or about July 17, 2023, employees were subject to an increased risk for severe injury due to both the potential fire and toxic chemical overexposure hazards posed by anhydrous ammonia under certain conditions as the employer did not document the equipment complies with Section 6.12.1 of ANSI/IIAR 2 - Standard for the Safe Design of Closed-Circuit Refrigeration Systems when the employer did not install an emergency shut-off switch with "ON/ AUTO" override capability, a tamper-resistant cover, and clearly marked by signage indicating its function for emergency ventilation outside of the engine room. A person who inadvertently shuts off the emergency shut-off during an actual emergency release puts other employees at risk of overexposure to anhydrous ammonia.  e) 8141 Seashore Highway, Bridgeville, DE (Engine Room, SE End of Facility): On or about July 17, 2023, employees were subject to an increased risk for severe injury due to both the potential fire and toxic chemical overexposure hazards posed by anhydrous ammonia under certain conditions as the employer did not document the equipment complies with Section 6.13.1 of ANSI/IIAR 2 - Standard for the Safe Design of Closed-Circuit Refrigeration Systems when the employer did not install visual alarm lights or an audible warning system inside and outside each entrance to the engine room, nor a remotely monitored alarm activated by a detector at concentrations of 25 ppm of higher inside the engine room. Failure to notify employees would delay possible corrective action, emergency evacuation, and emergency response exposing employees to an increased risk for overexposure to anhydrous ammonia.   f) 8141 Seashore Highway, Bridgeville, DE (Engine Room, SE End of Facility): On or about July 17, 2023, employees were subject to an increased risk for severe injury due to both the potential fire and toxic chemical overexposure hazards posed by anhydrous ammonia under certain conditions as the employer did not document the equipment complies with Section 6.14.3.6  of ANSI/IIAR 2 - Standard for the Safe Design of Closed-Circuit Refrigeration Systems when the employer did not equip the exhaust fans in the engine room with non-sparking blades. Failure to ensure that the machinery room exhaust fans are non-sparking could result in unintended ignition of ammonia vapors during a release. Employees work on or near ammonia equipment of a regular basis. Failure to ensure that the machinery room exhaust fans are non-sparking could result in unintended ignition of ammonia vapors during a release. In the event of a release, sparking blades could ignite anhydrous ammonia in the air at concentrations between the UEL and LEL resulting in employee death or severe burn injuries.  g) 8141 Seashore Highway, Bridgeville, DE (Engine Room, SE End of Facility): On or about July 17, 2023, employees were subject to an increased risk for severe injury due to both the potential fire and toxic chemical overexposure hazards posed by anhydrous ammonia under certain conditions as the employer did not document the equipment complies with Section 6.14.7.4  of ANSI/IIAR 2 - Standard for the Safe Design of Closed-Circuit Refrigeration Systems when the employer did not make provisions for employee notification at a remote location in the event of unexpected loss of power to or failure of the normal or emergency mechanical ventilation system or upon activation of an ammonia leak detector. Employees are at increased risk for overexposure to anhydrous ammonia or severe injury due to the ignition of accumulating ammonia vapors.  (h) 8141 Seashore Highway, Bridgeville, DE (Engine Room, SE End of Facility): On or about July 17, 2023, employees were subject to an increased risk for severe injury due to both the potential fire and toxic chemical overexposure hazards posed by anhydrous ammonia under certain conditions as the employer did not document the equipment complies with Section 6.15  of ANSI/IIAR 2 - Standard for the Safe Design of Closed-Circuit Refrigeration Systems when signage such as NFPA 704 placards, alarms, restricted access, and emergency control switch did not exist. Failure to provide appropriate signage such as restricted personnel access to machinery room could lead to unauthorized employees accessing / operating anhydrous ammonia equipment without proper training resulting in a loss of containment.

Issued

2024-01-12 00:00:00

Abate by

2024-02-08 00:00:00

Penalty

Initial $15625.00 · Current $0.00 Reduced

Hazardous substances 01700175

General-duty citation text

29 CFR 1910.119(e)(3)(v): The process hazard analysis did not address the hazards related to facility siting:   a) 8141 Seashore Highway, Bridgeville, DE (Anhydrous Ammonia Refrigeration Process Control Room): On or about July 17, 2023, the process hazard analysis did not address the impact of toxic releases of anhydrous ammonia on the Control Room, a critical area of the building that is occupied by refrigeration technicians, who conduct emergency operations. The intent of this building, as designed, was not as a shelter-in-place location for protecting employees from toxic exposure to anhydrous ammonia or a fire involving the ignition of ammonia vapor.

Issued

2024-01-12 00:00:00

Abate by

2024-02-08 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 01700175

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not assure that PHA recommendations were resolved in a timely manner:  a) 8141 Seashore Highway, Bridgeville, DE  (Anhydrous Ammonia Refrigeration Process): On or about July 17, 2023, the employer's established system, with respect to their 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 Item 85 RECOMMENDATION(S) - Ensure the charging SOP has a step to check if the truck pump discharge has a relief valve to relieve back to the truck in an overpressure situation. (b) PHA Item 95 RECOMMENDATION(S) - If no procedure exists, create an SOP or maintenance procedure for proper mixing / concentration of glycol and adding to system. (c) PHA Item 194 RECOMMENDATION(S) - Evaluate current replacement / inspection of hoses and adjust if necessary. A compromised hose could break, releasing ammonia into the production area around the plate coils with subsequent. (d) PHA Item 199 RECOMMENDATION(S) -  Compare the list of current SOPs with the refrigeration equipment list. Develop any missing SOPs such as for the -30F Plate Freezer Vertical Pump Receiver.  (e) PHA Item 213 RECOMMENDATION(S) - Confirm there is a written oil draining procedure for each oil pot. (f) PHA Item 221 RECOMMENDATION(S) - Ensure annual evacuation drills occur. Should have an after-action review / debrief to evaluate things that went wrong and things that went right during the drill.  (g) PHA Item 223 RECOMMENDATION(S) -  Ensure SOPs are reviewed and certified with input from CIMCO and operators. (h) PHA Item 230 RECOMMENDATION(S) -  Recent ventilation study shows significant issues such as fan speeds are not at the proper velocity, spark producing blades are used, and ventilation is not connected to detection. Ensure that these items have been corrected or are corrected as soon as possible.

Issued

2024-01-12 00:00:00

Abate by

2024-02-08 00:00:00

Penalty

Initial $15625.00 · Current $0.00 Reduced

Hazardous substances 01700175

General-duty citation text

29 CFR  1910.119(h)(2)(iv): The employer did not develop and implement safe work practices consistent with paragraph (f)(4) of this section to control the entrance, presence and exit of contract employers and contract employees in the covered process areas.   a) Simmons Animal Nutrition, Inc., Bridgeville, DE - On or about July 13, 2023, the employer did not implement a safe work practice to authorize the entrance and exit through an open gate of contract employees who perform work on or in areas adjacent to anhydrous ammonia refrigeration equipment. These employees would not be accounted for in the event of an emergency as they are not utilizing a sign-in sheet.

Issued

2024-01-12 00:00:00

Abate by

2024-02-08 00:00:00

Penalty

Initial $15625.00 · Current $0.00 Reduced

Hazardous substances 01700175

General-duty citation text

29 CFR 1910.119(n): The employer did not establish and implement an emergency action plan (EAP) for the entire plant in accordance with the provisions of 29 CFR 1910.38 for handling small releases.   (a) Facility: On about July 17, 2023, the employer failed to establish and implement an EAP in accordance with the provisions of 29 CFR 1910.38 for handling small releases.  (b) Facility: On about July 17, 2023, the employer failed to establish and implement an EAP describing procedures to be followed by employees who remain to operate critical plant operations before they evacuate when handling small releases; (c) Facility: On about July 17, 2023, the employer failed to establish and implement an EAP describing clear procedures for reporting of ammonia releases and fire, or who is to sound an evacuation alarm; and, (d) Facility: On about July 17, 2023, the employer failed to establish and implement an EAP describing procedures for emergency evacuation, including type of evacuation and exit route assignments.

Issued

2024-01-12 00:00:00

Abate by

2024-02-08 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 01700175

General-duty citation text

29 CFR  1910.120(q)(2): The employer did not develop an emergency response plan for emergencies which addressed the following minimum requirements of this standard: 1910.120(q)(2)(i) through 1910.120(q)(2)(xii):  a) 8141 Seashore Highway, Bridgeville, DE: On or about July 17, 2023, the employer's emergency response plan was not coordinated in advance with local responders such as the Bridgeville Fire Department to determine in advance what roles would be taken by each in the event of an ammonia release or fire as required by 29 CFR 1910.120(q)(2)(i).  b) 8141 Seashore Highway, Bridgeville, DE: On or about July 17, 2023, the employer's emergency response plan did not provide contact information for all employees, such as department supervisors who are considered emergency contacts  in the event of an ammonia release or fire as required by 29 CFR 1910.120(q)(2)(i).  c) 8141 Seashore Highway, Bridgeville, DE: On or about July 17, 2023, the employer's emergency response plan did not consider safe distances and places of refuge for an emergency that included the release of large amounts of ammonia or fire as required by 29 CFR 1910.120(q)(2)(iv).   d) 8141 Seashore Highway, Bridgeville, DE: On or about July 17, 2023, the employer's emergency response plan had not developed and implemented an emergency alerting and response procedure that would recognize the difference between an ammonia release and other types of emergencies as required by 29 CFR 1910.120(q)(2)(ix).

Issued

2024-01-12 00:00:00

Abate by

2024-02-08 00:00:00

Penalty

Initial $15625.00 · Current $0.00 Reduced

Hazardous substances 01700175

General-duty citation text

29 CFR  1910.119(o)(4): The employer did not promptly determine and document an appropriate response to each of the findings of the compliance audit, nor document that deficiencies have been corrected:  a) Simmons Animal Nutrition, Inc., Bridgeville, DE (Ammonia Ammonia Refrigeration Process): On or about July 17, 2023, the employer did not promptly document the corrections for deficiencies (items listed below) identified in their 2021 compliance audit, exposing employees to fire and toxic hazards posed by anhydrous ammonia in the event of an uncontrolled release  (a) Item 60 - Update the ventilation system calculations and upgrade ventilation system if needed. (b) Item 133 - Perform regular evaluations on all contractors that come onsite. (c) Item 155 - Perform Testing of Safety Devices as recommended by IIAR, OEM's, etc. Develop an ongoing maintenance program that will indicate how often the testing should be performed. (d) Item 174 - Conduct testing from PMs put into systems. (e) Item 199 - Implement a Action Item List and conduct regular PSM meetings. (f) Item 252 - Have equipment calibrated and documents added to PSM program.