Several of our UFCW members who work in meatpacking, poultry and food processing plants spend their days working around refrigeration systems that use ammonia – a Highly Hazardous chemical. It is easy and important for stewards to find out if their company is complying with OSHA’s standards about how to operate safely with Highly Hazardous chemicals. The main standard is Process Safety Management (PSM). PSM gives workers and their representatives the right to ask for information about the ammonia system.
OSHA’s PSM Standard applies to most meat packing, poultry, and food processing plants. One PSM requirement is that the company must conduct an audit of their compliance every three years. Stewards can request to see the recommendations from the past two audits and find out what actions have been taken. By looking at the audit results and the follow-up stewards can see if the company is taking their PSM seriously.
“When I was sent out for training, I received a lot of information about PSM that I realized could be helpful to not only me, but also my co-workers at the plant,” said Jim Oldenburg, a steward at JBS and a member of UFCW Local 1473 in Green Bay, Wisconsin.
Even though every worker at the plant cannot receive specialized PSM training, workers do have the right to stay informed about their plant’s PSM program and come to their stewards with questions or concerns. To help his co-workers at the plant, Oldenburg submitted a list of PSM questions and responses to the company. These questions were developed by the Industrial Refrigeration Consortium at the University of Wisconsin – Madison.
“People look to me to help them and I’m doing everything that I can for them every day. Having this information available is just one of them,” said Oldenburg.
Here are the ten questions Jim submitted to management. According to the PSM standard your company must respond adequately to your concerns. Their responses to these questions can give you a sense of the condition of your plant’s ammonia safety program. If you need help evaluating the company’s response you can email the UFCW Health and Safety Representative for Process Safety Management at firstname.lastname@example.org.
1. When was our last compliance audit?
2. Can you show me the closeout of recommendations from the last compliance audit?
3. Can you provide me a copy of the most recent incident report and documentation that shows how we closed out recommendations/from the incident report?
4. When was our last Process Hazard Analysis (PHA) conducted and can you show me documentation that closes out the recommendations from the last PHA?
5. How often do we certify our plant’s written operating procedures for the covered process?
6. What training program do we have for our operators and what are the means used to verify they have understood the training?
7. How often do we do refresher training?
8. Based on our plant’s mechanical integrity program, what is the next piece of equipment scheduled for retirement and when is it scheduled to come out of service?
9. What criteria do we use to evaluate contractors that work on our covered process?
10. What was the last change made to our system and can you show me the documentation for that change?