Many UFCW members in meatpacking, poultry and food processing plants may not be aware that they work around anhydrous ammonia – a highly hazardous chemical that could trigger an evacuation of their plant as well as the surrounding community.
Under OSHA’s Process Safety Management Standard, workers and their representatives have special rights to action and information in every facility with over 10,000 pounds of ammonia. Most plants that have to cool large storage or production areas use well over 10,000 pounds in their ammonia refrigeration systems.
Since an ammonia release could affect workers in any area of the plant, stewards can benefit from a basic knowledge of the hazards of ammonia and the steps the employer must take to protect workers.
The Process Safety Management Standard gives stewards the right to ALL information the company has about their ammonia refrigeration system. The company also has to have a system in place for workers to express their concerns and to receive responses about those concerns.
“Anhydrous ammonia is a deadly material,” said Jeff Dillener, a steward at Cargill and member of UFCW Local 230 in Ottumwa, Iowa. “As a UFCW steward, I have been trained to follow exact procedures in handling this material so that I can keep my fellow workers safe from harm.”
Every three years, the company has to conduct an audit of their compliance with the Process Safety Management regulations. Stewards can request to see the recommendations of the past two audits. If the company is carrying over the same recommendations from one audit to the next, that’s a good indication that they are not taking their own Process Safety Management program seriously.
The regulations for highly hazardous chemicals are different from the general health and safety regulations for regular production operations. One of the big differences is that breakdowns are not acceptable in ammonia refrigeration systems. Components of the ammonia refrigeration system must be replaced BEFORE they reach their breaking point! Every component of an ammonia refrigeration system (including the miles of piping on the roof) should have an estimated life cycle and a scheduled replacement date. This system of fixing things before they break is called Mechanical Integrity. Since ammonia refrigeration systems are closed systems, the ammonia never should get out of the system into the air. A leak or a release is an indication that the system is not being maintained the way the law requires it to be.
An important provision of the Process Safety Management Standard is the requirement for the company to think through changes to the system BEFORE they make those changes. They must document this process, which is called Management of Change. OSHA has made it very clear that personnel changes, such as changes in staffing levels, hours, outsourcing and training, that have an impact on the ammonia refrigeration system must go through the Management of Change process. Members can ask to be part of this process and weigh in on the possible consequences of the change being considered. This is a way for workers to fight dangerous reductions in Refrigeration Technician staffing levels or dangerous increases in mandatory overtime. Contact the UFCW Health and Safety Office at (202) 223-3111 for information about training.