In Darling Ingredients, Inc. v. OSHRC, the Fifth Circuit upheld citations issued to Darling Ingredients, Inc. after a fatal accident at its chicken-rendering plant in Byram, Mississippi. Two employees died during maintenance on a pressurized steam machine known as a hydrolyzer when the machine unexpectedly released high-pressure steam and material. OSHA cited the company for failing to clearly and specifically outline safety procedures under the lockout/tagout standard at 29 C.F.R. § 1910.147.
The accident occurred in August 2020 while maintenance workers attempted to unclog the hydrolyzer. After several attempts to reduce pressure through normal procedures failed, the team removed a bolted flange. The resulting depressurization released hot steam and material, severely burning three workers. Two of them later died.
Following an investigation, OSHA cited Darling under two subsections of the lockout/tagout regulation. The agency found the company failed to clearly specify steps to safely control hazardous energy and to outline shutdown, isolation, and securing procedures. According to OSHA, the written instructions simply stated workers should "[r]elieve internal pressure" without describing how.
Darling argued that its procedures were adequate when read with the hydrolyzer manual and employee training. The company also claimed workers deviated from established practices and that the incident resulted from unforeseeable misconduct.
The court rejected these arguments, citing precedent that lockout/tagout procedures must be sufficiently detailed to stand alone and provide clear direction to employees. It found that Darling’s policies lacked specific steps or fallback instructions and did not reflect the facility’s actual practices. The court also noted that waiting for pressure to dissipate was the only safe option, yet it was not mentioned in the procedure.
The court further concluded that Darling had constructive knowledge of the violation. Darling had written and reviewed the hydrolyzer procedure, and OSHA had previously cited the company for similar violations at other facilities. That history, combined with the lack of written guidance at Byram, supported the finding that Darling knew or should have known its policies were deficient.
The court upheld the classification of the violations as repeat offenses, noting that prior citations involved the same regulatory provisions and similar energy control hazards, even if the specific machines differed. The court emphasized that the hazard—exposure to uncontrolled energy—was substantially the same.
Finally, the court found that Darling waived its independent employee misconduct defense by failing to raise it at trial or provide supporting evidence.
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