Imperial Sugar Responds

Port Wentworth, GA – Imperial Sugar has a demonstrated track record of a commitment to safety prior to the February 7, 2008 accident at the Port Wentworth, Georgia facility.  Prior to the accident, the company voluntarily hired outside consultants to review and suggest safety enhancements and took other steps to address deal with dust generation and dust control.

Several recent news articles, however, have overlooked many of the steps taken to protect the Port Wentworth employees prior to the accident. For example, an article in the Savannah Morning News on April 7, 2009 contained an allegation that certain “experts” told Imperial Sugar about “defects in the sugar dust control system” at its Port Wentworth plant. 

That allegation overlooks the fact that Imperial voluntarily hired Custom Technical Solutions (CTS) in 2006 to assist the company with a capital project relating to improving the facility’s wet dust collection system.  In late 2006, CTS also conducted a partial assessment of the dry dust collectors that serviced the plant’s powder mill. The issues identified during its review of the dry dust collectors were related primarily to a single component of the collectors—blow rings.

In response, the plant’s supervisors increased inspection and maintenance of the blow rings and made adjustments to other connected components.  Through these efforts, the issues relating to the blow rings were resolved prior to the February 7 accident.  The plant continued regular ongoing maintenance of the dust collectors as well.  In addition, the company elected to commission a more comprehensive evaluation of its dust collectors, which culminated in the hiring of MacAljon Engineering (MacAljon) in 2007.

It is critical to note that neither the CTS nor the MacAljon report warned Imperial about any hazards associated with combustible dust at the Port Wentworth plant.  Instead, these reports, generated at the company’s request, focused on technical issues surrounding the performance of the plant’s dust collection system. Neither report contained any kind of warning to the plant that any specific deficiencies in the dust collection systems were causing the emission of hazardous dust.  It is also important to note that the MacAljon report was not reviewed by the recipient until after the February 7, 2008 accident – the report was dated February 5, 2008 and was sent to Imperial on February 6, 2008, and the recipient did not review the report until after the accident.

As outlined below, this work was one of several measures taken by the Port Wentworth plant to evaluate dust generation and dust control.  Indeed, while working to improve its dust collectors, the Port Wentworth plant also focused on housekeeping, including more cleaning specifically related to dust in response to OSHA’s publication of its National Emphasis Program on combustible dust. 

For Further Information

OSHA has alleged that Imperial of willfully violating OSHA regulations in connection with their inspection of the catastrophic accident at the Port Wentworth plant on February 7, 2008.  Managers, supervisors, and employees at the plant, many of whom have worked there for decades and personally lost friends and relatives in the tragedy, know better.

Imperial has contested the OSHA citations because the company was diligently and consistently working to improve the safety of its facilities for its employees and contractors.  Lost amid the legal whirlwind to assign blame for this tragic accident have been some key facts: 

Port Wentworth’s Safety Record and OSHA Inspection History

  At the time of accident, the Port Wentworth plant’s “injury rate” had dropped by 33% since 2005. 

  OSHA inspected the plant only twice before the accident (in 2000) and issued no citations against Imperial.

Reviews of the Port Wentworth Facility by Agencies Other than OSHA

  In each of the 5 years before the accident, the American Institute of Bakers audited the plant for cleanliness and compliance with food safety standards and issued “superior” ratings—its highest possible rating. 

  In 5 inspection reports issued in 2007 by the Georgia Department of Agriculture, the agency identified no significant housekeeping issues or violations relating to how the physical facilities were “installed, maintained, and cleaned.” 

Imperial’s Safety Training and Management Programs

At the time of the accident, the Port Wentworth plant had implemented and was maintaining a robust safety program, including: 

  The plant was on course toward having all managers and supervisors trained through OSHA’s 30-Hour Course (which trains employees on a wide range of safety and health hazard recognition and prevention).  By late 2007, almost 50% had completed the course.

  The plant maintained a “First Responder Team” of over 50 employees who attended a 40-hour course on such topics as emergency response, first aid/CPR, fire prevention and protection, and incipient fire response.

  All plant employees attended an initial 8-hour safety training course and annual “birthday month” safety training on safety policies, hazard recognition, and safe work practices.

  The plant maintained an active Safety Steering Committee, made up of hourly employees, who reviewed safety practices and procedures, advised the Safety Department and Plant Manager on safety concerns, and developed action plans to improve safety.

  The plant maintained an internal safety audit system, and by late 2007, had developed a system requiring two daily walk-through inspections by the Plant Manager and Safety Manager, and operational managers were held accountable via progress reports. 

Imperial’s Capital Expenditures on Safety-Related Improvements

  In FY 2007 alone, the plant spent over $1.7 million on safety-related capital improvements.

  Before the accident, the plant had budgeted almost $1 million in safety-related capital projects for FY 2008.

  These capital expenditures were in addition to the safety-related expenditures made on a continuous basis as part of the general operating budget of the plant.

Imperial’s Response to OSHA’s National Emphasis Program on Combustible Dust

OSHA published its NEP in October 2007.  Although the NEP was a guideline for OSHA compliance officers regarding enforcement, the Port Wentworth plant promptly took steps toward complying with the NEP guidance, including forming a multi-disciplinary team of managers and supervisors, developing a list of action items, and working to complete those items.  Many of the action items were completed or ongoing at the time of the February 2008 accident, such as: 

  Concentrating efforts by the maintenance and electrical departments to study production facilities, identify root causes of dust emissions, and eliminate those causes;

  Identifying a source of leaks (2-lb sugar bucket elevator), and approving a capital project ($80,000.00) to replace it with a vertical screw conveyor system;

  Hiring MacAljon Engineering for a comprehensive analysis of the dust collection system;

  Improving the plant’s housekeeping program, focusing on dust-prone production areas;

  Purchasing new industrial vacuums, as recommended in OSHA’s NEP, for use in cleaning dust and minimizing airborne disbursement;

  Increasing the frequency of audits and daily walk-through inspections throughout the plant to identify and correct housekeeping deficiencies; and

  Initiating various facility improvements, including several fire safety improvements.

Imperial’s Plans for Rebuilding and Setting the Industry Standard in the Management of Combustible Dust Hazards

Imperial is rebuilding its Port Wentworth plant.  With the help of leading experts in various fields, Imperial is building a state-of-the-art facility that will include safety features going well beyond what is specifically required.  Hundreds of millions of dollars will be invested to accomplish these goals. 

Among other experts, Imperial has engaged Chilworth Technology, a leading consultant regarding the hazards of combustible dust, to perform comprehensive reviews, provide training, and advise on design strategies to eliminate combustible dust hazards.  The new plant in Port Wentworth will deploy the most advanced systems for dust collection and sugar conveyance, and be designed to limit and control hazards related to combustible dust. 

Imperial’s unwavering resolve is to build and operate the safest sugar refinery in the world.  Our employees should expect no less.  For over ninety years, the company has employed hundreds of men and women from Port Wentworth and surrounding communities.  For some local families, several generations of family members have worked at the plant.  Following the tragedy of February 7, 2008, we were proud to be able to continue to retain and pay our employees.  Upon completion of the new facility, we look forward to a promising future for our employees.