It is good that we are finding fewer and fewer facilities without pressure testing and leak testing records on their process piping. But now comes the difficult question:
Is pressure and leak testing required after maintenance or alterations on piping systems?
So, most companies will have their newly installed piping pressure tested and leak tested by the contractor who performed the installation. But two months into operating said piping, some maintenance work is necessary and this work will require us to OPEN the piping system, make repairs, and then return the piping to service. How many of you will include some type of integrity testing on this circuit of piping that has been opened/altered/repaired BEFORE we return it to service?
Using my favorite Piping Maintenance RAGAGEP, API 570, we can see that... (emphasis by me)
Six people were confirmed dead in a boiler explosion at a wood factory in the southern province of Dong Nai on May 1, 2024. The accident also injured five others.
The provincial People's Committee has offered condolences and financial support to the victims' families (20 million VND or 789 USD for each fatality and 10 million VND for each injury).
The incident occurred at around 8:30 a.m. The injured are receiving treatment at hospitals in the province, and further investigations are being conducted.
In the world of industrial safety, we are not at a loss for the desire to try new things. Many consulting companies are waiting to sell us their shiny gadgets. One of these latest crazes is called "SIF"—Serious Injuries and Fatalities. The concept behind this model is based on the progress many have made in reducing their recordable injuries of lesser severity; however, the risk of a significant incident may still be present. Take OSHA data, for example; as a nation, we have seen a drastic drop in "OSHA recordable" injuries, but we have not seen the same drop in fatalities. So the thought process is that we need to IDENTIFY those risks that can lead to a serious injury or fatality (SIF) and analyze the controls/barriers/safeguards we have in place AND their real-time ability to PREVENT, PROTECTION, and/or MITIGATE these SIF events.
Most of us are already informally doing SIF. I like to start my clients out with their BIG THREE:
Ammonia is held for sale by a retailer in a large storage tank. The retailer sells ammonia as an agricultural fertilizer and a coolant for air conditioning systems.
Section 311(e)(5) of EPCRA exempts from the definition of a hazardous chemical "(a)ny substance to the extent it is used in routine agricultural operations or is a fertilizer held for sale by a retailer to the ultimate customer."
For purposes of EPCRA sections 311/312 reporting, how would this combined usage of the ammonia tank be affected by the agricultural use exemption under EPCRA section 311(e)(5)?
The Department of Homeland Security’s Chemical Facility Anti-Terrorism Standards (CFATS) impose comprehensive federal security regulations for high-risk chemical facilities.
Do the CFATS alter the requirements that apply to a facility covered under both CFATS and either the Emergency Planning and Community Right-to-Know Act (EPCRA) or the Clean Air Act §112(r) (i.e., the Risk Management Program (RMP))?
The current list of delegated states and counties is:
NOTE: Kentucky, Puerto Rico, and the Virgin Islands no longer implement the program, and the regional office has taken over the implementation of those areas.
These requirements control the release of hazardous energy while workers service, maintain, or repair machines or equipment when activation, start-up, or release of energy from an energy source is possible; proper control of hazardous energy prevents death or serious injury among these workers.
I have written about the risks associated with the desire to use larger CO2 containers in the restaurant industry. The IFC now has a section related to the hazards associated with these larger cylinders. Still, most of the code deals with CO2 leaks causing an oxygen-deficient atmosphere, much like what happened in AZ McDonalds.
But there is another catastrophic risk associated with these "dewars"... failure of the vessel. This is what happened in this event at a restaurant over the weekend.
A "dewar" stores the CO2 in a pressurized liquid state, so much more volume is available than the older CO2 compressed gas cylinders. This improves "efficiency" but also increases risks in an industry where workers are usually not aware of the risks.
The failure mode of this dewar is unknown, but we can see from the images and video that it appears to be a failure of the bottom weld, which launched the container upward through the building, landing in the parking lot some 300' away. It destroyed the restaurant (empty at the time of the event) and cause serious structural damage.
High-Hazard Group H Occupancy High-hazard Group H occupancy includes, among others, the use of a building or structure, or a portion thereof, that involves the manufacturing, processing, generation or storage of materials that constitute a physical or health hazard.
Hazardous occupancies are classified in Groups H-1, H-2, H-3, H-4 and H-5.
High-hazard Group H-1 buildings and structures that contain materials that pose a detonation (explosion) hazard. High-hazard Group H-2 buildings and structures contain materials that pose a deflagration or accelerated burning hazard. High-hazard Group H-3 buildings and structures that contain materials that readily support combustion or pose a physical hazard. High-hazard Group H-4 buildings and structures which contain materials that are health hazards. High-hazard Group H-5 semiconductor fabrication facilities and comparable research and development areas in which hazardous production materials (HPM) are used and the aggregate quantity of materials is in excess of those listed in Tables 5003.1.1.(1) and 5003.1.1(2).
Here is a summary of the requirements and their code citations:
Much like it is in process safety, the Management of Change (MOC) tool may be the most despised element of an SMS. However, a recent safety assessment with a local client identified the lack of performing an MOC on significant changes to production machinery and rates. The facility is NOT a PSM facility, but they are ISO45001 "certified."
Last year, the facility had four (4) recordable hearing loss cases (e.g., a loss of 25 dBs), which got corporate asking questions. I was contacted to see if I could investigate and determine the causes that led to these recordable illnesses. Of course, I started with the written HCP and all the required actions the plan calls for. I immediately noticed that the facility's HCP stated an attenuation evaluation would be done for each type of HP provided; the facility had not conducted this evaluation. As it turns out, the HP being provided could only attenuate exposures to less than 90 dBA, not the required 85 dBA for those who had suffered an STS. And almost 50% of the employees in the HCP had suffered an STS over the previous three (3) years -YES, that is very high percentage!
I then went to the exposure data, where the wheels came off!
The facility had undergone many "improvements" and growth over the previous four (4) years. The business consolidated three facilities into one and moved into a new building. However, the business has not updated its Noise Survey and Personal Sampling with the new building and equipment layouts. Add this to the fact that the HP being provided was inadequate! The business immediately hired an IH firm to come in and perform some noise sampling to establish exposures. Management was not happy and began to point fingers at the OSH manager. But this professional had plenty of evidence that he/she had made it clear that a new building, new machines, new layout of the machines, etc. would need an MOC to manage this change. Remember, this is an ISO45001 certified facility.