OSHA Inspection: SIMMONS ANIMAL NUTRITION INC.

Issued

2024-09-06 00:00:00

Abate by

2024-10-31 00:00:00

Penalty

Initial $16131.00 · Current $12098.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(d)(2)(i)(C):  Information concerning the technology of the process did not include a maximum intended inventory of highly hazardous chemicals:  At the worksite located at 832 E 3rd Street, Milan, MO 64556:    The employer failed to protect employees from hazards related to highly hazardous chemicals at the facility.  This was most recently documented on May 13, 2024, and at times prior thereto when the employer did not document the maximum intended inventory of anhydrous ammonia, highly hazardous chemical (HHC) expected in the covered process at any time. The employer was unaware of their maximum quantity of HHC for their ammonia refrigeration system at the facility.

Issued

2024-09-06 00:00:00

Abate by

2024-10-31 00:00:00

Penalty

Initial $16131.00 · Current $12098.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(d)(3)(i)(B): The employer's piping and instrument diagrams were not accurate and did not represent equipment that was existing and was part of the process.   At a worksite at 832 E 3rd Street, Milan, MO 64556:   The employer failed to protect employees from hazards related to highly hazardous chemicals at the facility. Employees engaged in repairing, replacing, operating, inspecting, testing, and maintaining covered process equipment were exposed to toxic, cryogenic, and fire hazards in the event of an anhydrous ammonia release. This was last demonstrated on or about May 13, 2024, and at times prior thereto, when the following equipment including, but not limited to piping, valves, pressure vessels, safety devices and instruments that were existing and part of the ammonia refrigeration system were not reflected in matching piping and instrument diagrams (P&ID).  a) A compressor "HS-2" was marked in the filed as such but was reflected on PID-06 as HSC2.  b) A compressor "HS-2" hand unknown valve type associated with the compressor marked 102125 in the field and was not reflected on PID-06 with no other identification information provided.  c) A high temperature recirculator "HTR-1" had an angle valve associated with a pump that was marked on HTR1-51 in the field but was reflected as 43 on the PID-09 with no other identification information provided.    d) A high temperature recirculator "HTR-1" had an angle valve associated with a pump that was marked on HTR1-49 in the field but was reflected as 35 on the PID-09 with no other identification information provided.    e) A high temperature recirculator "HTR-1" had an angle valve associated with a pump that was marked on HTR1-27 and LTR-01 in the field but was reflected as 13 on the PID-09 with no other identification information provided.    f) A low temperature recirculator "LTR-1" had a check valve associated with a pump that was marked on LTR-38 in the field but was reflected as 28 on the PID-10 with no other identification information provided.    g) A low temperature recirculator "LTR-1" had a relief valve associated with a sight glass stack that was marked on LTR-16 in the field but was reflected as 48 on the PID-10 with a tag number of 102612.  h) A low temperature recirculator "LTR-1" had an angle valve associated with a pump that was not marked in the field but was reflected as 37 on the PID-10 with no other identification information provided.    i) A low temperature recirculator "LTR-1" had an angle valve associated with a pump that was not marked in the field but was reflected as 39 on the PID-10 with no other identification information provided.   j) A low temperature recirculator "LTR-1" showed an angle valve with a gage that was associated with a pump that did not exist in the field but was reflected as 39 on the PID-10 with no other identification information provided.   k) A low temperature recirculator "LTR-1" showed an angle valve with a gage that was associated with a pump that did not exist in the field but was reflected as 40 on the PID-10 with no other identification information provided.   l)  A low temperature recirculator "LTR-1" had a pressure relief valve associated with a sight glass stack that was marked on LTR-16 with a set pressure of 150 p.s.i. in the field but was reflected as 48 with a set pressure of 250 p.s.i. on the PID-10 with no other identification information provided.

Issued

2024-09-06 00:00:00

Abate by

2024-10-31 00:00:00

Penalty

Initial $11524.00 · Current $8643.00 Reduced

Hazardous substances 0170

General-duty citation text

1910.119(g)(3)  When PSM refresher training was provided, the employer did not prepare a record which contained the identity of the employee, the date of training, and the means used to verify that the employee understood the training.  At a worksite at 832 E 3rd Street, Milan, MO 64556:   The employer failed to protect employees from hazards related to highly hazardous chemicals at the facility. This was last demonstrated on or about May 13, 2024, and at times prior thereto, when the ammonia refrigeration technicians were not trained on operating procedures. Employees engaged in repairing, replacing, operating, inspecting, testing, and maintaining covered process equipment were exposed to toxic, cryogenic, and fire hazards in the event of an anhydrous ammonia release.  a) Employees were not trained in the safety systems and their functions associated with the ammonia refrigeration system. This included, but was not limited to gas doctors, alarms, pressure gages, temperature gages, float switch, level probes, temperature probe, and pressure probes.  b) Employees were not trained in the emergency shutdown procedures for equipment and related components associated with the ammonia refrigeration system. This included, but was not limited to pressure vessels, evaporators, condensers, piping, and hoses.

Issued

2024-09-06 00:00:00

Abate by

2024-10-31 00:00:00

Penalty

Initial $16131.00 · Current $12098.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(f)(1): The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements:  [A] Initial startup  [B] Normal operations  [C] Temporary operations  [D] Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner  [E] Emergency operations  [F] Normal shutdown  [G] Startup following a turnaround, or after an emergency shutdown  At a worksite at 832 E 3rd Street, Milan, MO 64556:   The employer failed to protect employees from hazards related to highly hazardous chemicals at the facility. This was last demonstrated on or about May 13, 2024, and at times prior thereto, when the ammonia refrigeration technicians were not provided with complete written operating procedures with clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and did not address all of the elements under A-G of this standard.  a) A standard operating procedure for the "E-11" West Plate Freezer Room was found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address any of the elements under A-G.  b) A standard operating procedure for the "E-14" #1 Cooler - Real Pet was found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address all of the elements under A-G, this included information on valves associated with the equipment.  c) A standard operating procedure for the "E-15" #2 Cooler - Real Pet was found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address all of the elements under A-G, this included information on valves associated with the equipment.  d) A standard operating procedure for the "E-19" #6 Cooler - Real Pet was found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address any of the elements under A-G.  e) A standard operating procedure for the "E-20" #6 Cooler - Real Pet was found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address any of the elements under A-G.  f) A standard operating procedure for the "E-23" #7 Cooler - Real Pet was found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address any of the elements under A-G.  h) A standard operating procedure for the "E-33" -10 F Freezer #1 was found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address all of the elements under A-G, this included information on valves associated with the equipment.  i) A standard operating procedure for the "E-35" to "E38" were found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address any of the elements under A-G.  j) A standard operating procedure for the "E-46" -25F Freezer #2 was found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address all of the elements under A-G, this included information on valves associated with the equipment.  k) A standard operating procedure for the "E-51" -10F Holding Freezer #3 was found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address all of the elements under A-G, this included information on valves associated with the equipment.  l) A standard operating procedure for the "PF-04" Plate Freezer was found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address all of the elements under A-G, this included information on valves associated with the equipment.  m) A standard operating procedure for the "PF-08" Plate Freezer was found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address all of the elements under A-G, this included information on valves associated with the equipment.  n) A standard operating procedure for the "PF-10" Plate Freezer was found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address all of the elements under A-G, this included information on valves associated with the equipment.  o) A standard operating procedure for the "PF-11" Plate Freezer was found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address all of the elements under A-G, this included information on valves associated with the equipment.  p) A standard operating procedure for the "E-16" Plate Freezer was found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address any of the elements under A-G.  q) A standard operating procedure for the "VT-1 Surge Drum" to "VT-4 Surge Drum" were found to be incomplete and lacked clear instructions for safely conducting activities in accordance to process safety information and did not address any of the elements under A-G.

Issued

2024-09-06 00:00:00

Abate by

2024-10-31 00:00:00

Penalty

Initial $11524.00 · Current $8643.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR  1910.119(i)(1): Pre-startup safety review was not performed when modifications to existing facilities significant enough to require a change in the process safety information were made:  At a worksite at 832 E 3rd Street, Milan, MO 64556:   The employer failed to protect employees from hazards related to highly hazardous chemicals at the facility. This was last demonstrated on or about May 13, 2024, and at times prior thereto, when the pre-startup safety review (PSSR) did not confirm that all of the subsection (i)-(iv) involved in operating a process had been completed prior to the introduction of highly hazardous chemicals to the process.  Employees engaged in repairing, replacing, operating, inspecting, testing, and maintaining the covered process equipment were exposed to toxic, cryogenic, and fire hazards in the event of an anhydrous ammonia release.  a) A Management of Change (MOC) completed June 6, 2023, for "MC-34412" showed a change was performed to optimize the plate freezer cooling - defrost sequencing the valve timers will be adjusted to optimize the operation of the units. Documentation of the set points for the timers will be noted and creation of Plate Freezer Operation procedure. A PSSR was not performed for the associated MOC by the employer.   b) A Management of Change (MOC) completed June 12, 2023, for "MC-34409" showed a change was performed to E-46 Freezer 2 unit is being removed from the system. A PSSR was not performed for the associated MOC by the employer.    c) A Management of Change (MOC) completed June 5, 2023, for "MC-33775" showed a change was performed to Upgrade and bring the engine room ventilation and detection system up to code. Attaching full scope of work - demo old ventilation system installing two new exhaust fans, occupancy fan, detection system, controls, strobes and horns. A PSSR was not performed for the associated MOC by the employer.   d) A Management of Change (MOC) completed March 15, 2024, for "MC-158956" showed a change was performed to Installing 2 solenoid king valves in engine room on the HPL line from HPR/Condensers to CPR & MTR along with 2nd valve to isolate compressor liquid cooling lines. A PSSR was not performed for the associated MOC by the employer.

Issued

2024-09-06 00:00:00

Abate by

2024-10-31 00:00:00

Penalty

Initial $16131.00 · Current $12098.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(j)(4)(iii): The frequency of inspections and tests of process equipment to maintain its mechanical integrity, was not consistent with applicable manufacturer's recommendations and good engineering practices, or more frequently determined to be necessary by prior operating experience.     At a worksite at 832 E 3rd Street, Milan, MO 64556:    The employer failed to protect employees from the hazards of highly hazardous chemicals associated with ammonia refrigeration that are used daily. This was last demonstrated on or about March 18, 2023, and at times prior to that. The employer did not follow the recognized and generally accepted good engineering practices (RAGAGEP). The employer failed to protect employees because the employer did not inspect and test piping systems (piping components such as pressure relief valves, isolation valves, instrumentation) to ensure that they were maintaining the ongoing integrity of process equipment.   a) A pressure relief valve"HTR1-16" marked on P&ID 09 for the refrigeration system was not adequately maintained in that pressure relief valves (PRVs) were not being inspected or replaced every five years. There was a Hansen PRV that was scheduled to be replaced in July 2023, and had not been replaced, or taken out of service, nor had the employer taken any further steps to ensure safe operations. The valve is connected to the High Temperature Recirculator (Model # H5604).   b) A pressure relief valve"HTR1-55" marked on P&ID 09 for the refrigeration system was not adequately maintained in that pressure relief valves (PRVs) were not being inspected or replaced every five years. There was a Hansen PRV that was scheduled to be replaced in July 2023, and had not been replaced, or taken out of service, nor had the employer taken any further steps to ensure safe operations. The valve is connected to the High Temperature Recirculator Oil Pot (Model # H5601).   c) The low temperature recirulator "LTR1" marked on P&ID 10 for the refrigeration system was not adequately maintain in those portions of system equipment, piping and its interconnected components were not kept free from excessive ice buildup. Ice was permitted to accumulate in quantities that could deflect or bend pipes, displace components, or negatively impact the system's structural integrity.  This hazardous condition exposed employees engaged in repairing, replacing, operating, inspecting, testing, and maintaining covered process equipment to toxic, cryogenic, and fire hazards in the event of an anhydrous ammonia release.

Issued

2024-09-06 00:00:00

Abate by

2024-10-31 00:00:00

Penalty

Initial $11524.00 · Current $8643.00 Reduced

Hazardous substances 0170

General-duty citation text

29 CFR 1910.119(j)(5): The employer did not correct deficiencies in equipment that were outside acceptable limits (defined by the process safety information on paragraph (d) of this section) before use.  At a worksite at 832 E 3rd Street, Milan, MO 6455:   The employer failed to protect employees because the employer did not correct deficiencies in equipment that were outside of acceptable limits. This was last demonstrated on or about October 21, 2022, and at times prior to that. This hazardous condition exposed employees engaged in repairing, replacing, operating, inspecting, testing, and maintaining covered process equipment to toxic, cryogenic, and fire hazards in the event of an anhydrous ammonia release.  a) A pressure gauge for the "13" compressor marked on PID-06 was not in good working order as it wasn't visible or legible, and had not been replaced, or taken out of service, nor had the employer taken any further steps to ensure safe operations. The gauge readings were not visible for equipment located on the HS4.    b) An evaporator "45" in freezer #2 for the refrigeration system was not adequately maintained in those portions of system equipment, piping and its interconnected components were not kept free from excessive ice buildup. Ice was permitted to accumulate in quantities that could deflect or bend pipes, displace components, or negatively impact the system's structural integrity.   c) An evaporator "33" in freezer #1 for the refrigeration system was not adequately maintained in those portions of system equipment, piping and its interconnected components were not kept free from excessive ice buildup. Ice was permitted to accumulate in quantities that could deflect or bend pipes, displace components, or negatively impact the system's structural integrity.  d) In the engine room of the facility, the employer failed to adequately maintain equipment when the employer stored a pallet holding (3) 55-gallon drums, containing combustible refrigeration oil, in the engine room placed near the main entrance and exit route to the engine room. The presence of oil, a combustible material, within the engine room could enlarge a fire initiated by the ignition an ammonia vapor cloud within the engine room under the right conditions.  e) In the engine room of the facility, the employer failed to adequately maintain equipment when the employer did not ensure that piping was insulated for piping and equipment surfaces not intended for heat exchange did not contain intact insulation, nor had it been treated, or otherwise protected to mitigate condensation and excessive frost buildup for the "BC4" Compressor where the surface temperature is below the dew point of the surrounding air during normal operation and in an area where condensation and frost could develop and become a hazard to occupants or cause damage to the structure, electrical equipment, or refrigeration system.  f) In the engine room of the facility, the employer failed to adequately maintain equipment when the employer did not ensure that piping was insulated for piping and equipment surfaces not intended for heat exchange did not contain intact insulation, nor had it been treated, or otherwise protected to mitigate condensation and excessive frost buildup for the "HTR1" Vessel where the surface temperature is below the dew point of the surrounding air during normal operation and in an area where condensation and frost could develop and become a hazard to occupants or cause damage to the structure, electrical equipment, or refrigeration system.  g) In the engine room of the facility, the employer failed to adequately maintain equipment when the employer did not ensure that piping was insulated for piping and equipment surfaces not intended for heat exchange did not contain intact insulation, nor had it been treated, or otherwise protected to mitigate condensation and excessive frost buildup for the "LTR1" Vessel where the surface temperature is below the dew point of the surrounding air during normal operation and in an area where condensation and frost could develop and become a hazard to occupants or cause damage to the structure, electrical equipment, or refrigeration system.  h) A pressure relief valve "HPR-33" on the roof for the refrigeration system was not adequately maintained in those portions of system equipment, piping and its interconnected components where a pressure relief valve discharge termination to atmosphere was not less than 7.25 ft (2.2 m) above a roof that is occupied solely during service and inspection. In addition, there was a higher adjacent roof level within 20 ft (6.1 m) horizontal distance from the relief discharge, the discharge termination was also less than 7.25 ft (2.2 m) above the height of the higher adjacent roof. Ammonia vapor being discharged in the area could accumulate and become a hazard to occupants performing inspection of the equipment for the ammonia refrigeration system.   i) An ammonia line "EQ" 3' marked on PID-01 was not in good working order as it was experiencing excessive corrosion and pitting, and had not been replaced, or taken out of service, nor had the employer taken any further steps to ensure safe operations. The piping is connected to the HPR and located under the EC-5 and EC-6 condensers.

Issued

2024-09-06 00:00:00

Abate by

2024-10-31 00:00:00

Penalty

Initial $11524.00 · Current $8643.00 Reduced

General-duty citation text

29 CFR 1910.119(e)(5): The employer did not establish a system to promptly address the PHA team's findings and recommendations:  At a worksite at 832 E 3rd Street, Milan, MO 6455:   The employer failed to protect employees from hazards related to highly hazardous chemicals at the facility. This was last demonstrated on or about May 13, 2024, and at times prior thereto, when the employer's established system, with respect to their most recent Process Hazard Analysis (PHA), did not assure 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 those findings and recommendations for a 5-year PHA Revalidation. This exposes employees to fire and chemical overexposure hazards posed by anhydrous ammonia in the event of an uncontrolled release.