Get to know your STKY chemicals (Asphyxiants)
There are two (2) types of Asphyxiants:
These different types of asphyxiants behave differently and cause harm differently. Read more ... Add new comment
Get to know your STKY chemicals (Cl2)
Chlorine is EXTREMELY HAZARDOUS, with an IDLH of 10 ppm and a TLV of 0.5 ppm (just above the odor threshold for most). Chlorine is heavier than air (VD > 2.5), and when released, it forms a greenish-yellow gas with a pungent, irritating odor that follows the terrain at ground level. The mean odor threshold for chlorine lies between 0.2 and 0.4 ppm. Chlorine is a NON-FLAMMABLE gas; however, it is a powerful oxidizing agent, reacting explosively or forming explosive compounds or mixtures with many common chemicals. Chlorine immediately reacts with both organic and inorganic materials it comes into contact with to form chlorides. The primary route of exposure is INHALATION. Chlorine is very volatile, with a Boiling Point of -29°F. So, although it is shipped as a liquefied gas under pressure, once the primary containment is breached, it will quickly become a GAS. The Vapor Pressure of Cl2 is 6,450 mm hg @ STP. Remember, BP and VP have inverse relationships. As BP goes down, VP goes up, and vice versa. An excellent standard to follow is that water at STP has a VP of 25 mm hg and a BP of 212°F. Cl2 is the opposite: it has a high VP (6,450 mm hg) and a Low BP (-29°F).
The Protective Action Distance makes sense when you see this
An image from my HAZMAT courses... People wonder why the ERG Protective Action Distance diagram is shaped like it is. This image validates the model...
NOTE: Cl2 release image is from the Jack Rabbit testing project Human Factors in incident investigations assessment tool
Here is a GREAT "self-assessment" tool, just eight (8) questions, to evaluate your facility's ability to investigate and perform causal analysis properly. Appeals Court sides with Paper Mill over Confined Space incident
This is a crazy case! The mill hired a contractor to build scaffolding inside one of its Chlorine Dioxide (CLO2) tanks. The mill prepped the tank and even performed the initial air sampling of the space. Turned it over to one of the scaffolding contractor employees who would be the attendant for the entry. Three entrants and the attendant were wearing personal Cl2 air monitors. Three scaffolding builders entered the tank. After 30-40 minutes, one of them felt ill and exited the tank. Once outside his personal detector alarmed. Soon after, the other two workers' detectors went into alarm, and they exited the tank. Two entrants were hospitalized for two (2) days; the other two were treated and released. The employee who filed the suit continued to suffer symptoms from chlorine dioxide exposure, including excessive coughing and wheezing. He was diagnosed with bronchiolitis obliterans and upper airway injuries. He sued the mill, the company that made the personal detectors, and the company that supplied the detectors. So far, he has lost his case. This was his appeal, but it did not go well. The paper mill claimed they had no control over the event, even though it was their tank on their property. This post is NOT about limiting liability but about managing PRCS entry hazards. I will note that the meters' manufacturer presented evidence that two of the monitors detected chlorine dioxide limits that would have put them into alarm, but the monitors were switched off less than two minutes later. This happened several times over 24 minutes for one monitor and 33 minutes for the other. As noted above, their final inspection of the monitors before they were sold to the rental company had low alarm settings at 0.10 ppm and high alarm settings at 0.20 ppm. By the time of the incident, the settings had been changed to 0.20 ppm and 0.50 ppm. Safway employees stated that they had not changed the settings. The presumption is that the rental company changed them. Here is all the legal wrangling! OSHA finds Florida contractor ignored federal safety measures that could have prevented welder’s confined space fatality (O2 Deficiency)
As he had many other days, the morning shift welder arrived at 5 a.m. to work on Aug. 28, 2023. Tasked with doing some fabrication work in a 4-foot by 8-foot space in a ship’s hull, the employee began work unaware that fatal suffocation would soon end his life. Less than two hours after entering the ship, a supervisor found the unconscious welder and signaled for help, only to fall unconscious as well. A third employee appeared, alerting EMS and the local Fire Department, who soon transported all three workers to a nearby hospital. Despite emergency treatment, the welder died from a lack of oxygen. The supervisor and the third worker received medical treatment and were released. OSHA CSHOs determined the employer exposed workers to oxygen deficiency by sending the welder into a confined space without testing the air for oxygen content. The presence of welding gas in the space created an oxygen-deficient atmosphere. OSHA investigators found that in addition to a lack of oxygen, the shipbuilder also exposed workers to struck-by and crushing hazards by failing to conduct annual inspections of six cranes. The agency cited the company with four serious violations and has proposed $55,539 in penalties, an amount set by federal statute. The company has contested the findings before the independent Occupational Safety and Health Review Commission. Citations are below... Comparison of Tier II, TRI, and 112(r) Requirements (TCEQ)
The Emergency Planning and Community Right-to-Know Act (EPCRA) requires businesses that store and/or manufacture, process, or use certain chemicals to complete the Tier II (EPCRA 311 and 312) Report and/or the Toxics Release Inventory (EPCRA 313) Report, also called the Form R. Section 112(r) of the Clean Air Act focuses on risk management for accident prevention. While these three (3) programs have similar reporting elements, they have significant differences outlined in the following table. How do you differentiate between an amputation without bone and avulsions?
How do you differentiate between an amputation without bone and avulsions? Portable Fire Extinguishers Standard (Annual Maintenance Certification Record)
Paragraph (e)(3) of the 1910.157 specifies that employers must subject each portable fire extinguisher
In addition, this provision requires employers to retain the inspection record for
and to make the record available to OSHA on request. This recordkeeping requirement assures workers and agency compliance officers that portable fire extinguishers located in the workplace will operate normally in case of fire; in addition, this requirement provides evidence to OSHA compliance officers during an inspection that the employer performed the required maintenance checks on the portable fire extinguishers.
Its the little things that matter... open top or bung top container
I have written many articles discussing evacuating hazardous materials from a piping system. Over my career, I learned that using an open-top container can have disastrous results. It may sound silly or petty, but when something fails in the tasks and the hazardous material erupts from the open-top container, making contact with the worker(s), you will begin to ask... is there a better way? And I will bet someone will suggest a closed-top/bung-style container. Keep in mind that this is NOT preventing the event/failure that makes a bung top drum a safety device, but it could be a protection layer and most certainly would be considered a mitigation layer should we have an eruption from the container. When using the bung style drum, remember to ALWAYS have it vented so as to not "launch" the drum, making it a hazard. We always used the 2" bung for our hose/sparger and the 0.5" bung for our "vent". These bung drums also slow the liberation of gas/vapors from our absorbent material (usually water or caustic). So give it some consideration; it may just be the ticket for those unexpected "surges" caused by improper energy isolation or blockage breaking free in the piping. The same application is used for 5-gallon containers such as "draining oil" from a refrigeration "oil pot" where sputtering is not uncommon. But remember, VENTING is critically important. We can lay a rag over the vent to reduce splash/sputter from the opening; it can also help reduce odors and off-gassing - BUT NEVER BLOCK the vent with any mechanical device or leave it plugged/closed.
PRCS Fatality (O2 Deficiency)
At 5:00 p.m. on September 20, 2023, an employee entered an oil well production tank to replace a leaking valve. The employee became unconscious when he entered the confined space. The employee died of asphyxiation in the hazardous atmosphere. |
Partner Organizations
I am proud to announce that The Chlorine Institute and SAFTENG have extended our"Partners in Safety" agreement for another year (2024) CI Members, send me an e-mail to request your FREE SAFTENG membership
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