Potentially Deadly Chemical Hazards
OSHA’s recent inspection of the Reinhart Food Service facility in Taunton, MA highlights the importance of complying with the process safety management standard to prevent the release of potentially deadly chemical hazards. Responding to employee complaints, OSHA found that a faulty check valve leaked about 9 pounds of anhydrous ammonia and the ammonia sensor in the pump room was not functioning properly. The facility’s refrigeration system uses 27,500 pounds of anhydrous ammonia. Exposure to even as little as 300 parts per million of anhydrous ammonia is immediately dangerous to life and health. The OSHA permissible exposure limit is 50 ppm while the American Conference of Industrial Hygienists (ACGIH) Threshold limit value is 25 ppm and the short term exposure limit is 35 ppm.
Ammonia is a colorless gas with a strong, sharp, irritating odor. When concentrated, it is corrosive to tissues upon contact. Exposure to ammonia in sufficient quantities can be fatal. The lowest level at which humans can detect the odor of ammonia, approximately 5 ppm, generally provides sufficient warning of exposure; however, persons with prolonged exposure to ammonia can lose their ability to detect the odor (olfactory fatigue). Contact can severely irritate and burn the skin and eyes with possible eye damage. Inhaling ammonia can irritate the nose, throat and lungs. Higher exposures may cause a build-up of fluid in the lungs (pulmonary edema), a medical emergency. Repeated exposure can result in an asthma-like allergy and lead to lung damage. Contact with liquid ammonia can cause frostbite. Ammonia is used in fertilizers, as a refrigerant, and in making plastics, dyes, textiles, detergents, and pesticides.
OSHA’s inspection of Reinhart identified several deficiencies in its process safety management program, a comprehensive and effective program that covers processes in the workplace involving large amounts of highly hazardous chemicals.
OSHA identified the following deficiencies:
- Inadequate procedures for inspecting, testing and replacing valves and ammonia sensors consistent with the manufacturer’s recommended safety procedures.
- Not ensuring that ammonia sensor alarms worked properly.
- An inadequate emergency response plan.
- Not ensuring that employees who responded with and provide support to hazardous materials technicians demonstrated competency.
- Not taking adequate precautions to identify responders’ maximum exposure limits to ammonia.
Facilities with processes that utilize specific hazardous chemicals above the listed threshold quantity must comply with OSHA’s process safety management standard, 29 CFR 1910.119. The standard addresses unexpected releases of highly hazardous chemicals including toxic, reactive, or flammable liquids and gases from processes. Serious incidents continue to occur in a variety of industries that use highly hazardous chemicals that may be toxic, reactive, flammable, or explosive, or may exhibit a combination of these properties. Regardless of the industry using these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly managed. This, in turn, can result in a disaster.
From my experience, chemical sensors installed in facilities are often neglected and fail to function properly. Chemical sensors require periodic calibrations based on the manufacturers instructions and the OSHA standards. Having sensors that are not working, places employees’ lives at risk. Sensors need to also be tested periodically and the employees need to know what the alarm sounds like and steps to take in the event the alarm is triggered. Employee training and conducting drills are key to ensuring a safe workplace.
The main provision of the standard is a process hazard analysis (PHA) that involves a compilation of process safety information. A PHA is a thorough review of what could go wrong and the safeguards that must be implemented to prevent releases of hazardous chemicals.
OSHA’s inspection also identified two other hazards:
unsecured and inadequately anchored large steel commercial storage racks that could have fallen and struck or crushed employees and unclosed openings on electrical cabinets and boxes.
As a result of its findings, OSHA cited Reinhart Food Service on April 20, 2016, for six serious and two repeated violations of workplace health standards.
The company faces a total of $72,000 in proposed penalties.
Reinhart is the fourth largest foodservice distributor in the U.S., supplying independent restaurants, delis, sporting venues, schools, nursing homes, hospitals, the military and chain accounts. Founded in 1972, in La Crosse, Wisconsin, Reinhart Food Service is based in Rosemont, Illinois. The company operates 29 distribution centers nationwide, and a USDA-inspected fresh meat processing facility.
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Leon Levine, MS, CIH LEED AP – Principal Consultant
Leon is a certified industrial hygienist (CIH) with extensive experience managing environmental health and safety projects ranging from residential and commercial indoor air quality (IAQ) investigations to large scale development and implementation of global corporate programs and databases to minimize risks to building occupants, workers and communities. Leon began working in the environmental field in 1991 conducting research on contamination and bioaccumulation of heavy metals in the Boston harbor. Having worked at the U.S. Occupational Safety and Health Administration for several years, Leon is highly experienced in interpreting and applying federal, state and local regulatory requirements in controlling environmental exposures. Leon worked on numerous projects evaluating and addressing environmental contamination associated with the World Trade Center (WTC) attacks as well as Anthrax threats. Feel free to contact him at firstname.lastname@example.org