Swift Historical Perspective • Marriage between Safety and Engineering (good engineering practice) – Involved Corporate Engineering and Plant Engineers • Training, Training, and more Training – Initial.

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Transcript Swift Historical Perspective • Marriage between Safety and Engineering (good engineering practice) – Involved Corporate Engineering and Plant Engineers • Training, Training, and more Training – Initial.

Swift
Historical Perspective
• Marriage between Safety and Engineering (good
engineering practice)
– Involved Corporate Engineering and Plant
Engineers
• Training, Training, and more Training
– Initial training of PSM Implementers (Primatech)
– Use of checklists that clarify what progress really is
– Operator training on Ammonia Systems
(IIAR/RETA)
– Training Engineers on MOC with Ammonia CER’s
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Historical Perspective
• Keeping PSM on the Front Burner
– Quarterly progress reports on PHA and CA
• Deficiencies (signed by plant manager)
– Facility safety reviews
– Monthly conference calls
• Auditing, Auditing, and more Auditing
– Plants performed self-audits per CPL checklist
– Corporate Safety and Engineering did PSM
audits
– Third party audits
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Historical Perspective
• OSHA PSM Inspections
– Wallace, NC was first on 1/96 by State OSHA
– Turlock, CA was second on 1/97 by State
OSHA
– Kansas City, KS was third on 5/97 by Federal
OSHA
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The Inspection Process
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Kansas City, KS
• Processed meats facility producing:
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Deli products
Sliced luncheon meat
Breakfast strips
Sausage franks
– Lunchmakers®
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Constructed 1979, addition 1996
225,000 square feet
55,000 pound ammonia system
Four system operators
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Original Complaint Investigation
January 8,1997
• “The ammonia piping and valves on the
manufacturing floor of the plant are
deteriorated and in very dangerous condition
exposing employees to injury.”
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Very brief inspection
No review of PSM
No interviews
No citations issued
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Second Complaint Investigation
April 9, 1997
• “Manufacturing floor, evaporative units 1 through
6 have valves that are deteriorating, stems that are
1/3 their original size, and have severe corrosion
problems.”
• “Some pipes in the engine room are schedule 40
rather than standard schedule 80.”
• “Pipes and pressure vessels are welded on by noncertified welders.”
• “Pipes in the facility are not tested for corrosion.”
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Initial Inspection
• One inspector from Overland Park office
• Minimal visits to inspect physical conditions
– takes video and still pictures
• Requests and receives numerous documents including:
– pipe inspection report
– mechanical integrity program
– process hazard analysis and status report
– completed compliance audits
• Interviews operators
– interviews each operator for up to four hours
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Salt Lake City Inspection Team
• Four inspections
– original inspector (Safety Engineer)
– Assistant Regional Director (Industrial
Hygienist)
– Salt Lake City inspectors:
• Mechanical Engineer (PE/Industrial Hygienist)
• Industrial Hygienist (CIH)
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Team Inspection Process
• Request and receive numerous additional
documents
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inspectors pair up to focus on specific elements
continue interviews with operators
group interview with management
several tours to view engine room, roof, and
pipe runs
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Documents Furnished
• All PSM program elements and supporting
information including:
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all Management of Change forms
equipment manuals
all PSM incident investigation reports
all employee training records for operators
ancillary programs (LOTO, PPE, confined
space, etc.)
– ConAgra Annual Report
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Additional Issues
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Asbestos survey
PSM consultant
Pipe radiography
Pipe replacement
Full corporate safety and health compliance
audit
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Inspection Management
• Request all documents in writing
• 24 hour time to respond
• Log all documents given
– name of document
– file number
– double copy
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KANSAS CITY, KANSAS - PSM INSPECTION
AREA OF CITATION
Employee Participation
Process Safety Information
Process Hazard Analysis
Operating Procedures
Training
Contractors
Pre-Startup Safety Reviews
Mechanical Integrity
Management Of Change
Incident Investigation
Compliance Audits
Total PSM
# ITEMS CITED
2
3
3
7
2
2
4
7
4
3
3
40
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KANSAS CITY, KANSAS - PSM INSPECTION
AREA OF CITATION
Related H&S Programs
OSHAct General Duty - Section 5 (a)(1)
Emergency Action Plans - 1910.38
HAZWOPER - 1910.120
Personal Protective Equipment - 1910.132
Respiratory Protection - 1910.134
Control of Hazardous Energy
(Lockout) - 1910.147
Employee Alarm Systems - 1910.165
Electrical Safety - 1910.303, 304, & 305
Total Related H&S Programs
TOTAL ITEMS CITED
# ITEMS CITED
1
1
1
1
2
4
1
2
13
53
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PreCitation Settlement
• Potential for megafine and negative
publicity
• Interest by OSHA
– leverage inspection
– avoid potential conflict with VPP Partnership
Initiative
– save resources
• UFCW informed and cooperative
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PreCitation Settlement
• OSHA provides draft citation
• ASE develops abatement plan
– aggressive dates
– $500,000 + spent on mechanical integrity and
PSM implementation
• Abatement plan reviewed with UFCW
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Citation
• 53 serious items:
– 40 PSM
• $256,650 proposed fine
• 3 willful violations avoided
– mechanical integrity
– pre-startup safety review
– process hazard analysis
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Settlement Agreement
Corporate
• Region-wide: 5 plants
Kansas City, KS
Hastings, NE
Junction City, KS
Carthage, MO
Omaha, NE
• Citation to be training tool
– ASE
– ConAgra
– Industry groups
• Train UFCW
• Copies to all ASE facilities
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Settlement Agreement
Kansas City
• Full PSM implementation by 7/1/98
• Corporate Safety Department to monitor
progress
– on-site visits
– 60 day monitoring reports
• 3rd party audit on or before 7/1/99
• OSHA Institute training
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Settlement Agreement
Kansas City (cont.)
• Serve as benchmark
• 5-year inspection by 7/1/98
– IIAR Bulletins
– ANSI/ASHRAE
– Replace piping with wall thickness loss of 50%
or greater
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Settlement Agreement
Region VII
• Quarterly reports
• Compliance by 4/19/98
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employee participation
contractors (except safe work practices)
pre-startup safety reviews
hot work permit
management of change
incident investigations
emergency response
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Settlement Agreement
Region VII (cont.)
• Compliance by 10/9/99
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process safety information
process hazard analysis
standard operating procedures
mechanical integrity (except 3rd party visual
inspection (6 months))
– compliance audits
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OSHA’s
Press Release
• “… employers with ammonia refrigeration
PSM related programs are being notified of
OSHA’s intent to hold them accountable for
complying with the IIAR Bulletins.”
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EMPLOYEE PARTICIPATION
• The facility’s Employee Participation Guidelines did
not:
– Address employee consultations during PSM program
development
– Assign responsibility or authority for implementing PSM
– Establish methods for soliciting input from contract
employees regarding PSM
• The facility did not consult with employees on various
elements of PSM
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PROCESS SAFETY INFORMATION
• The facilities PSI Information did not include:
– A block flow or simplified process flow diagram
– The expected maximum inventory of site vessels
– Safe upper and lower operating limits for temperature, pressure,
etc.
– Expected results of deviations from safe upper and lower
operating limits
– Design codes and standards, materials of construction, etc., used
in system design
– Complete Process & Instrumentation Diagrams (P&ID’s)
– Electrical classification of machine rooms
– Information regarding ventilation system design
– Information regarding safety systems (e.g. interlocks, cutouts,
detection systems)
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PROCESS SAFETY INFORMATION
The facilities PSI Information did not include:
• Verification of good engineering practices in ammonia
system including:
– a) Location of the discharge of pressure relief valves
(PRV’s) for new system
– b) The size of common vent header for PRV’s
– c) Suitability of pipe and vessel insulation materials
– d) Installation of PRV’s on appropriate devices (#’s 3
and 25 accumulators)
– e) Location of king valves (not operable from floor &
no access platform)
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PROCESS SAFETY INFORMATION
• Demonstration of good engineering practice for of
electrical classification
– a) Engine room not classified
– b) No remote emergency stop switches in engine
rooms
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Process Hazard Analysis
• The facility’s initial (1994) Process Hazards Analysis (PHA)
did not:
– Identify, evaluate, and establish controls for the hazards
associated with the process
– Address previous PSM incidents
– Address engineering and administrative controls for the
following:
• detection methodologies for ammonia nor emergency ventilation
• PRV’s or their vent header sizing
• emergency isolation (king) valves or compressor emergency cut-off
switches
• mechanical integrity procedures
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Process Hazard Analysis (cont.)
• Address the consequences of failure of
engineering and/or administrative controls
• Address facility siting or human factors
• The facility’s initial (1994) Process Hazards
Analysis (PHA) did not:
– Promptly address all recommendations
– Discuss recommendations with refrigeration
operators
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Operating Procedures
• The facility did not have compete (SOP’s) for the
ammonia system
• The facility’s written SOP’s did not address:
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Normal operating procedures
Temporary operations
Emergency shutdown conditions
Procedures for isolation and control of engine room leaks,
including PPE
– Operating limits, i.e., flow rates, pressure limits, temperature
ranges, etc.
– Hazards of the chemicals used in the process
– Safety systems and their functions, i.e., emergency stop switches,
king valves, etc.
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Operating Procedure (cont.)
• The facility did not perform annual
certification of their SOP’s
• The facility had not developed and
implement safe work practices for:
– Contractors entering the facility
– Entering process equipment or piping
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Training
• The facility’s PSM training program did not:
– Require refresher training at least once every
three years
– Require consultation with employees regarding
the frequency of refresher training
– Document employee training on specific SOP’s
– Require verification of employee understanding
of SOP’s
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Contractors
• The facility’s PSM Contractor Safety
Program did not require:
– Evaluation of contractor safety performance
and programs prior to contract initiation
– Periodic review of contractor safety
performance
– Periodic evaluation of contractor safety training
programs
– Periodic evaluation of contractor employees
understanding safety training
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Pre-Startup Safety Reviews
• The Pre-Startup Safety Review for the new
ammonia system failed to confirm that:
– construction and equipment of process was in accordance
with design specifications
– P& ID’s were complete and verified as accurate
– Acceptance tests were performed on computer hardware &
software, protection devices including alarms, interlocks,
cutouts and level controls
– Safety, operating, maintenance, and emergency procedures
were complete
– PHA had been performed
– Employee training had been performed and understood
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Mechanical Integrity
• The facility’s Mechanical Integrity Program
contained the following deficiencies:
– No procedures for repair of process equipment
– No procedures for replacement of PRV’s
– Inspection and tests were not performed on
vessels, piping, PRV’s, emergency shutdown
systems, control systems, pumps and
compressors
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Mechanical Integrity (cont.)
– No documentation of inspection & tests on
process equipment
– The facility did not correct known deficiencies
in a safe and timely manner
– No procedures ensuring that new refrigeration
plant was installed to design specifications and
manufacturer’s instructions
– No procedures to ensure that maintenance
materials, spare parts and equipment were
suitable for the process applications
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Management of Change
• No requirement to establish and implement
written MOC procedures
• Numerous changes were implemented
without performing MOC’s
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Management of Change (cont.)
• Written MOC procedures did not assure that
the following issues were addressed:
– Technical basis for proposed changes
– Safety & Health considerations
– Modifications to operating procedures
• Failure to update process information and
operating procedures after implementing
MOC’s
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Incident Investigation
• Failure to develop an incident investigation
procedure that met the requirements of PSM
• Failure to investigate numerous PSM related
incidents
• Failure to train investigation teams in incident
investigation techniques
• Failure to include at least one member with
process knowledge on investigation team
• Failure to establish system to promptly address
and resolve investigation report findings
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Compliance Audits
• Failure to verify that procedures and practices
developed under the standard were being
following, i.e., failure to correct PSI issues
identified in earlier compliance audits
• Failure to include at least one member with
process knowledge on the audit team
• Failure to develop plan for resolution of
compliance audit findings
• Failure to resolve compliance audit findings in a
timely manner
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Related Work Practices
• OSHAct General Duty - Section 5 (a)(1)
– Failure to provide positive securing mechanism
for chain hoist on freezer doors
– Failure to maintain chain hoists on freezer
doors
• Emergency Action Plans - 1910.38
– Failure to train employees in changes to site
alarm system
– Failure to train employees in changes to
emergency egress routes
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Related Work Practices (cont.)
• Hazwoper - 1910.120
– Failure to develop an emergency response plan
that adequately addressed:
• Ammonia release and response criteria
• Protocols for Carbon Dioxide or Sulfuric Acid releases
• Methods for determining safe distances and places of
refuge
• Personal Protective Equipment - 1910.132
– Failure to perform workplace hazard assessment
for ammonia system repairs
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Related Work Practices (cont.)
• Respiratory Protection - 1910.134
– Utilization cartridge respirators in lieu of SCBA
during ammonia releases
– No procedures for emergency’s involving
sulfuric acid and carbon dioxide
– Failure to perform air sampling prior to
entering potentially hazardous atmosphere
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Related Work Practices (cont.)
• Control of Hazardous Energy (Lockout) - 1910.147
– Use of tagout procedure in lieu of lockout where lockout
was appropriate
– No specific lockout procedures for the following
equipment:
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Shirmatic unit in TRM Stuffing Dept
Cozzini Vacuum Hopper & Mill in TRM Stuffing Dept.
Various pieces of ammonia refrigeration equipment
Transfer of ownership procedures
– Failure to perform annual audits of lockout program
– Failure to verify employee understanding of lockout
program (as evidenced by numerous injuries of employees
while performing lockout)
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Related Work Practices (cont.)
• Employee Alarm Systems - 1910.165
– Alarm system was not capable of being heard throughout
the workplace
• Electrical Safety - 1910.303, 304, & 305
– Electrical services not identified
– Live electrical parts (operating above 50 volts) not guarded:
• Electrical box in Sizzlean area
• Electrical panel in old engine room
– Ground pin removed on fan in new engine room
– Damaged insulation on electrical cord (TRM Shiramatic)
– Receptacle on reeves drive (Sizzlean) not water tight,
electrical hazard during clean-up
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