Both the U.S. Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) are focusing on ammonia. Today we will reflect on lessons learned from recent enforcement actions by the agencies. Tomorrow we will review EPA’s new risk assessment for ammonia.
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No Release, but a Huge Fine Anyway
It’s hard to swallow a huge fine for what might have happened. But, as part of its efforts to comply with a presidential order to improve safety and security at chemical facilities, the EPA is hunting down companies that are required to develop risk management programs (RMPs) but have not even though there has not been a release at the facilities. Here’s what happened recently to one company.
Kugler Oil Company was recently fined $101,808 by the EPA for the failure to develop and implement an RMP at its agricultural fertilizer plant in Nebraska.
EPA inspectors found that the plant had more than 10,000 pounds of anhydrous ammonia in process and therefore was subject to specific RMP regulations that apply to companies that use or store large quantities of the fertilizer chemical. At the time of the inspection, the plant was using or storing approximately 620,000 pounds of anhydrous ammonia but did not have the proper RMP in place.
Two Things You Must Know About RMP
There are two things you need to know about EPA’s RMP:
- The RMP applies to any facility that has a listed substance above the threshold quantity in any single process at the facility. The listed substances contain 77 toxic chemicals with thresholds ranging from 500 pounds (lb) to 20,000 lb and 63 flammable substances with a threshold quantity of 10,000 lb.
- The EPA is in the process of revising RMP regulations with the changes slated to be published in December 2016.
OSHA Reels in a Big One
A seafood processor in Boston was recently fined $173,168 in part for the death of an employee from ammonia exposure. According to OSHA, the employee of Stavis Seafood, Inc., was overcome by an ammonia leak caused by a burst pipe in the company’s machine shop. OSHA inspectors determined that deficient design and lack of proper operation and maintenance for the machine shop’s ammonia refrigeration system and equipment exposed employees to a catastrophic release of ammonia.
Seven Steps to Prevent Ammonia Exposure
There are steps you can take to avoid such a huge fine, and more importantly, employee exposure to ammonia.
Step 1. Ensure proper containment of ammonia. OSHA said that there were large holes in the floor in the Stavis machine room and there was no door to separate the machine room from a maintenance/storage room to prevent the spread of ammonia vapor.
Step 2. Test and calibrate ammonia sensors following the manufacturer’s recommendations, a step Stavis failed to take.
Step 3. Establish and implement an adequate inspection schedule for pressure vessels. Stavis failed to do this at the cost of an employee’s life, a huge fine, and a boatload of bad PR.
Step 4. Label ammonia piping properly. This did not happen at Stavis.
Step 5. Provide a ventilation system sufficient to prevent possible combustion or explosion of ammonia vapors resulting from an ammonia release. Due to the lack of a proper ventilation system, according to OSHA, Stavis employees were exposed to fire and explosion hazards resulting from the release of ammonia from the refrigeration equipment,
Step 6. Ensure that your ammonia alarm system is working. According to OSHA, the ammonia alarm system in the Stavis machine room was disabled for prolonged periods of time, and the refrigeration equipment continued to operate while the alarm system was disabled.
Step 7. Train your employees in emergency evacuation procedures in the event of an ammonia release. According to OSHA, on one occasion when the Stavis facility was evacuated because of an ammonia release, none of the plant’s emergency response personnel were on-site to perform their duties as outlined in the facility’s Building Evacuation Plan.
Will EPA’s updated risk assessment for ammonia force OSHA’s hand to update its permissible exposure limit? Tune into tomorrow’s Advisor for a look at the issue.