ERP - Environmental Risk Professionals

Anhydrous Ammonia

Liquid anhydrous ammonia tanks for refrigeration/freezers in a facility are a pollutant hazard. Anhydrous ammonia is highly corrosive, and exposure may result in injuries such as chemical-type burns to the skin, eyes, and lungs, which can be fatal. Accidental releases can result from hose failure during ammonia delivery and improper operation, inspection, or maintenance of systems. Unprotected piping or system evaporators can be damaged by impact from moving products within a facility. Corrosion, erosion, upsets, and vibration in the system can also cause an accidental release. Anhydrous ammonia is a flammable gas and presents the potential for explosions at the right concentrations.

Wastewater Management

Water is required in most meat-handling processes, such as slaughtering, scalding, and handling blood, viscera, and hide. These processes produce wastewater containing animal waste, including blood, manure, and fat, pathogens including salmonella and parasite eggs, and pesticide residues from treating animals and their feed or pharmaceuticals for veterinary purposes. Improper slaughtering procedures, breaches in containment systems, and spills, leaks, or overruns of pipes, valves, pumps, and tanks can discharge wastewater and contaminate soil and groundwater.

Phosphorus Run-off

Washdowns of holding pens, slaughtering areas, trucks, and equipment are wet cleaning procedures that can contaminate wastewater effluent. This wastewater can carry animal wastes and the chemicals and detergents from cleaning products used to disinfect and sanitize. Phosphorus can enter wastewater from animal waste, including blood, trimmings, paunch contents, cleaners, sanitizers, and detergents. Phosphorus entering freshwater systems can harm aquatic life and cause natural resource damage.

Run-off and Soil Contamination from Holding Pens

Holding pens used to keep live animals before slaughter contain urine and fecal matter. Uncovered pens can be exposed to rain and polluted stormwater run-off, contaminating soil, and groundwater and impacting adjacent properties.

Solid Waste Management

Solid waste collected at processing facilities includes fecal matter from holding pens, the inedible parts of animals, blood, and other animal by-products. Animal parts may be separated, collected, and stored for other uses, such as rendering or by-products. Other wastes, such as fecal matter, are disposed of from transporting and handling areas. This waste can be a breeding ground for bacteria, viruses, and pathogens, and it can attract pests. Improper treatment or collection of waste or poor maintenance procedures could contaminate water systems and lead to third-party liability and natural resource damage.

Chemical Storage

A variety of chemicals may be used and stored at a facility, including pest control products such as pesticides and rodenticides, direct food additives or preservatives (nitrite) and color, indirect food additives such as peeling aids and defoaming agents, curing compounds for hyde preparation, cleaners and sanitizers, and building maintenance materials like paints and lubricants. Containment breaches, spills, or improper handling and disposal can lead to environmental liability. During storage, chemicals should be segregated according to compatibility. Incompatible materials can create hazards; for example, mixing acids and products containing chlorine can release toxic chlorine gas.

Nitrate

Animal waste and waste products from meat processing contain nitrate compounds, which can harm both environmental and public health. Nitrates can lead to algal blooms and dead zones, depriving marine ecosystems of the oxygen needed to sustain aquatic life. High concentrations of nitrates in drinking water can hinder a body’s ability to carry enough oxygen to cells, causing potentially severe human health problems.

Air Emissions

Rendering, waste incineration operations, and using boilers and smokehouses can produce hazardous air emissions and lead to environmental liability. Air pollution can contain volatile organic compounds (VOCs) and particulate matter.

Contractors Pollution Liability Can Provide Coverage For

On-site cleanup of new and pre-existing pollution conditions, including restoration costs

Off-site cleanup of new and pre-existing pollution conditions

Third-party claims for bodily injury and property damage

Third-party claims for cleanup

Defense of third-party claims

Both sudden and gradual pollution conditions

Business interruption resulting from pollution conditions

First and third-party transportation pollution liability

Aboveground and underground storage tanks

Non-owned disposal sites

Illicit abandonment

Crisis management

Emergency response

Loading and unloading

Natural resource damage

Claims Scenarios & Examples

A forklift at a meat packing facility accidentally struck a pipe carrying ammonia for refrigeration. Because there were no physical barriers around the pipe, the pipe ruptured. As soon as the leak was detected, workers were evacuated. Soon after, there was an explosion, causing extensive damage, including to the building itself. The forklift was considered the source of the ignition.

A delivery truck was taking six 300-gallon containers to a poultry plant when it leaked an organic peroxide that was being delivered. As a result, highways and major roadways were closed, 300 employees were evacuated, and four people working near the plant, including two construction workers, were hospitalized due to breathing issues.

A beef processing plant was found to be out of compliance with the Clean Water Act and discharging pollutants into a nearby creek, which killed over 24,000 fish. The plant also did not properly operate or maintain its facilities in a way for it to comply with environmental obligations. Water from the beef processing and rendering operations was conveyed to a wastewater treatment plant on-site and, after being treated, was discharged into a creek. As a result, the creek was contaminated with pollutants, including fecal coliform, phosphorus, ammonia, dissolved oxygen, and osmotic pressure, at levels that violated the maximum daily limits. The company was ordered to reconstruct the wastewater system, spend $6 million on a new wastewater treatment plant, pay $8 million in civil penalties and $100,000 in damages, and upgrade the plant operations and maintenance.

A slaughterhouse faced a class-action lawsuit filed by almost 700 county residents who claimed the company contaminated their drinking water wells and made people sick by spraying millions of gallons of waste that included feces, blood, and guts from chickens onto nearby fields. In addition, more than 20 homes downhill from the facility had unsafe nitrate levels, and one monitoring well exceeded the legal limit.

A meat processing plant accidentally released roughly 200 pounds of anhydrous ammonia when a section of piping had a buildup of hydrostatic pressure. As a result, a component ruptured, causing the release. All facility employees and neighboring businesses had to be evacuated, 30 people had to seek medical help, and 17 people were hospitalized. Freeway off-ramps and local streets had to be shut down as well. After the incident, a safety inspection was completed, and found several safety concerns in the maintenance and design of the anhydrous ammonia refrigeration system.

A poultry processing plant was sued for violating the Clean Water Act for dumping chicken parts, fats, grease, and other slaughter waste into storm drains and two tributaries of a local river. The plant was also found to be sending waste to a water treatment plant, where partially-treated and untreated waste was dumped in streams. The plant paid $330,000 to settle the claims and agreed to ongoing monitoring and providing emergency operation plans and a corrective action plan to ensure these discharges did not happen again.

Emergency crews responded immediately when an ammonia cloud was seen emanating from a mechanical room at a meat processing plant. A valve on a compressed tank had failed and caused a chemical spill. Residents within 1.5 miles of the plant were told to shelter in place for at least five hours. Along with this, roads in both directions were closed. Firefighters helped ground the fumes with a water curtain, and the hazmat team entered to shut off the leak. Cleanup crews had to be brought in to clean up the chemical spill. A pig processing facility was found to be discharging tainted stormwater that leads to a river. Pollutants released from the plant include waste oils, lubricants, fuels, grease, heavy metals, and more. A lawsuit was filed for violating the Clean Water Act and its stormwater permit and harming the river for recreational use. The plaintiff claimed the plant did not properly test and maintain the pollutant discharge prevention system.

Property Types

Meat Processing

Environmental Exposures May Include: