Allen Family Foods, Inc.- Hurlock - Executive Summary |
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ALLEN FAMILY FOODS, INC. Allen Family Foods, Inc. (Allen's) operates and maintains a poultry-processing plant in Hurlock, Maryland. "Our mission is to create a safe work environment that encourages positive attitude by communicating honestly, directly and precisely with trust and respect for one another as we work and achieve a common goal which includes a quality product for our customers." We emphasize safety in line operation, contractor selection and emergency response. Our employees are trained to inspect, maintain and operate our equipment to prevent a release of hazardous material. We have developed and implemented an Emergency Response Plan with a goal to minimize hazards to all employees, visitors and persons in the vicinity. Poultry-processing requires significant refrigeration which is accomplished via the use of anhydrous ammonia at Allen's Hurlock Plant. This plant has a RMP Program 3 status for the operation of its ammonia refrigeration system used for cooling. T he Program 3 requires preparation of a worse case release scenario for the toxic material stored at this site. The worst case would be the release of a 14,000-pound storage tank of ammonia. The toxic endpoint would be 1.5 miles downwind. The alternative case for an ammonia release is a 5-pound/minute (lb/min) release for 65 minutes from a 6" pipe, which developed as a pinhole leak at a weld. Personnel knowledgeable of the site-specific refrigeration equipment and the process developed this scenario. RMP comp was used to calculate the end point based on the estimated time to discover the leak, to isolate the system and move the ammonia to another vessel. The estimated distance to the toxic end point for this release is less than 0.1 mile downwind which is to be reported as 0. Operators are trained to use self-contained breathing apparatus to respond to ammonia release. Allen's has implemented a Process Safety Management (PSM) program which is designed to prevent or minimize the consequences of releases of ammonia at this site and complies with OSHA PSM regulation 29 CFR 1910.119. We maintain up to date piping and instrument drawings, Material Safety Data Sheets, and we have a written preventive maintenance program. We use a computerized database program to produce work orders for regular preventative maintenance, yearly inspections and to maintain a history of the refrigeration equipment. We use the International Institute of Ammonia Refrigeration (IIAR) inspection checklist for our yearly inspections. If any problems are identified, corrective action will be documented on the work order. Upon completion of the work order, entry into the database will provide a permanent record. We have developed and updated our PSM manual with extensive employee participation. We also use the database as a means to scheduled quarterly reviews with the PSM team to ensure that our PSM manual stays "a living document". The PSM manual includes our operating procedures, which are updated as needed and reviewed each year. Our operators are provided training relative to their respective duties. They receive both on the job training and outside instruction, all training is documented. A Process Hazard Analysis (PHA) study was conducted to identify and evaluate potential hazards. The studies are updated every 5 years or when needed due to a change in the process. Allens evaluates their PSM program by conducting compliance audits every three years using checklists developed by OSHA. During the last 5 years, only one injury has occurred associated with the ammonia refrigeration system at this plant. While performing routine maintenance, one refrigeration employee while wearing approved Personal Protective Equipment (PPE), gloves and respirator, received burns on his hands when an isolation shut off valve failed to close. The trained refrigeration technician was able to seal the leak. As part of Allens' procedure, an incident investigation was per formed which included a written summary of the events of the incident, calculations to determine the amount of product released (2.14 pounds), the conclusions of how and why it happened, recommendations on how to prevent both the injury and release and any follow-up required. All recommendations have been implemented which included new PPE equipment being used which includes sleeves to prevent any seepage into the gloves. All Allen's employees receive hazard communications training during orientation, which includes evacuation procedures, emergency release notification and alarm signal recognition. Allen's also has established an Emergency Response Team (Team) which is the first line of emergency response for the Hurlock facility. Employees designated as Emergency Response Personnel are trained at the First Responder level to respond to a release of ammonia. The makeup of the Team is diverse and includes refrigeration technicians trained in emergency shutdown procedures for the amm onia system. To facilitate quick response, all Team members have pagers. A one number pager system has been established which includes pager codes for both emergency response and practice drills. Allen's maintains a close relationship with the local fire company. The Plant will use 911 to notify appropriate outside agencies. The continued implementation of the PSM program at our Hurlock facility will identify any future needed safety changes |