Knowing and understanding our local Fire Departments capabilities
This is the lens through which we should view EMERGENCY RESPONSE and our local FD as the "primary responders." Just because we have a local FD (paid full-time or volunteer) does not mean we have the emergency services we need! Far too often, our "assumptions" about the fire service's capabilities far outstretch their actual abilities. Regarding firefighting, rescue, and EMS, as well as response times, staffing, and equipment, we may be shocked at what our local FD can and can NOT provide. The FIRST STEP in Emergency Planning is sitting down with the FD leadership on an ANNUAL basis to analyze our needs and their abilities to provide those needs in a TIMELY manner. CLICK HERE for a great article at Fire Rescue 1
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EPA RMP citations @ specialty chemicals facility (Flammables and Toxics & $1.4M)
Respondent is the owner and operator of the facility. On October 15, 2022, there was an incident at the Facility that resulted in an accidental release of approximately 17,598 pounds of Aluminum Triethyl (ATE). The Incident resulted in an on-site chemical fire at the Facility and a shelter-in-place for the surrounding community. The Respondent’s facility uses natural gas and by-products from refinery operations to produce specialty chemicals for detergents and cosmetics. The facility uses or produces several regulated flammables such as ethylene, propane, butane, propylene, ethane, hydrogen, methane, and pentane. The Respondent’s processes meet the definition of “process” and “covered process”, as defined by 40 C.F.R. § 68.3. The Respondent’s RMP program level 3 covered processes store or otherwise use a regulated substance in an amount exceeding the applicable threshold. Ethylene Oxide, Hydrogen Flouride, and Chlorine are “regulated substances” pursuant to Section 112(r)(2)(B) of the CAA, and the regulation at 40 C.F.R. § 68.3. The threshold quantity for the regulated substance, Ethylene Oxide, as listed in 40 C.F.R. § 68.130, is 10,000 pounds. The threshold quantity for the regulated substance, Hydrogen Flouride, as listed in 40 C.F.R. § 68.130 is 1,000 pounds. The threshold quantity for the regulated substance, Chlorine, as listed in 40 C.F.R. § 68.130, is 2,500 pounds. Respondent has greater than a threshold quantity of Ethylene Oxide, Hydrogen Flouride, and Chlorine in processes at the Facility, meeting the definition of “covered process” as defined by 40 C.F.R. § 68.3. EPA Findings of Violation Nitrogen cylinder catastrophically failed during refilling/pressurization
Two people were severely injured after a Nitrogen cylinder catastrophically failed during refilling/pressurization. Person 1 shut off the air and nitrogen gas supplies before yelling to the workshop to call the HSE leader (nurse). Person 2, who was holding the cylinder, suffered severe injuries to his legs and one hand. Person 3 was injured when the booster pump collided with his legs, probably after parts of the cylinder had hit it. Both the injured people were quickly taken care of by the nurse and other response personnel, first at the incident site and then in the Heimdal
The direct cause of the incident was that the nitrogen gas cylinder burst during pressurization because it was probably exposed to a pressure significantly above its design level. CUI leads to 1,100 gallon Naptha release
The investigation has found that the direct cause of the leak was corrosion under the insulation in a 4" pipe for heavy naphtha from the distillation tower. The lack of inspection and repair meant that the corrosion had continued long enough for a hole to form in the pipe. Piping and equipment in a refinery can be exposed to external and internal corrosion. To monitor and repair such damage, they are inspected at specified intervals. The pipe where the leak occurred had been removed from the maintenance program by mistake in 2008. This error was discovered in 2013, but instead of being restored to the program, the pipe continued to be let out of the equipment strategy. This pipe was accordingly last inspected for corrosion under its insulation in 2004. Safety Thought of the Week... A Safety Partnership
A safety partnership is defined as: Leadership, managers, and front-line associates jointly focus on safety and proactively work together in a business entity to minimize the possibility of harm and maximize safety performance. (Cooper, 2016) Creating a genuine safety partnership means management and the workforce jointly working towards achieving common and understood safety goals, with clear and consistent communication, efficient monitoring, reporting, and decisive action to investigate blockages and take the appropriate corrective action as needed. The key drivers for developing and maintaining a safety partnership are straightforward and involve: 2018 Bologna Italy LPG Tanker BLEVE
On August 6, 2018, at 1:35 pm, an event occurred at Km 4+300 of the road connection between Motorway A1 and Motorway A14 near Bologna (see picture 1 in Annex 1). The section of the road flows over an elevated structure above the urban road network below. Among the vehicles involved in the accidents, there were two ADR vehicles. A tractor with a semitrailer with an LPG class 2 tank that was traveling in the direction north, for reasons to be clarified, violently hit the column of vehicles stationary in the right lane. The driver of the LPG tank vehicle died immediately due to the impact (see picture 2 in Annex 1). The last vehicle in the row was a vehicle carrying paint solvents - class 3 flammable liquids – which leaked onto the road due to the impact and immediately caught fire (0.5 sec). The fire engulfed the LPG tank quickly, initially only the front and then totally. The flames continued to burn the LPG tank, and about 7 minutes a BLEVE occurred. (see pictures 3,4 in Annex 1). Because of the energy released and the overpressure and heat generated, the road infrastructure collapsed, and the neighboring structures/buildings were strongly affected (see pictures 5, 6, and 7 in Annex 1). In the end, one person died (the driver of the tank vehicle), and 95 persons were injured (all were admitted to the hospitals near the area). Among the injured persons, some police officers and emergency teams rushed to the accident area. Their timely intervention allowed for clearing the area before the explosion, thus reducing damages and saving all the other people present near the scene of the accident. CLICK HERE for the UN Report Most LOTO failures are Latent Organizational Failures - NOT Active Failures
This picture has caused quite the debate in the SAFTENG circle! Many comments in the SAFTENG LI and FB groups point towards the worker(s), which indicates the belief that this is an "Active Failure" of the worker(s) involved. Many of you would NOT believe the tales I could tell about what I have encountered in my travels in 20+ years of consulting. In the vast majority of these situations, where the failure is hard to believe, it is a Latent Organizational Failure that sets the stage for such silliness. The debate we should be having is… Scenario: The sign moves or falls off and exposes the START button, and I come along and push the button, killing/maiming the workers. Am I a killer? Did I violate any procedure/program/training?
Who is “responsible” for this failure? Who is “accountable” for this failure? If this set-up was discovered before or after an accident, what questions would you ask in the investigation and causal analysis? Does the facility have the ability to recognize this failure? Non-Entry rescue mechanical device
OSHA states the following about our non-entry rescue devices... The mechanical device used for emergency rescue must be designed and rated for human use. The standard specifies in paragraph 1910.146(k)(3)(ii) that the retrieval equipment must be designed for personnel. The performance-oriented nature of the standard allows flexibility as to the design specifications of the retrieval equipment itself. OSHA accepts certification by manufacturers as well as listing (as being tested) by Nationally Recognized Testing Laboratory (NRTL). An employer may design, manufacture, test, and certify (for example by a registered professional engineer) mechanical devices used for retrieval of personnel from a vertical space. NASA's Dirty Dozen
The Dirty Dozen highlights the most frequently observed human-related issues discovered during Fiscal Year 2022 agency mishaps and close-call investigations. Throughout the year, these issues contributed to $3,310,298.74 in damage costs and 630 workdays of lost time. NASA's Human Factors Analysis and Classifications System (HFACS)
In Reason’s Swiss Cheese model, there are four “slices "or tiers of human error potential, divided into two sections: an “active” layer and “Latent Factors”: preconditions, Supervision, and Organization. The goal of the Human Factors Analysis and Classification System (HFACS) is to understand human factors throughout the system rather than stopping at the operator. Most mishaps can be connected to human events at NASA, from 2010-2015, human events and conditions totaled 79% of causal factors identified in its mishaps and close calls. Consequently, NASA now requires the participation of a Human Factors Investigator in Type A & B mishaps and High Visibility Close Calls. These are Influences or Factors closely tied to the mishap and described as actions or inactions that result in a mishap. There are four (4) areas in this active layer, and these are: CSB's Accidental Release Reporting (40 CFR 1604)
This is a reminder that if your ERP or Environmental Management System (EMS) has not been updated to reflect these "NEWER" CSB reporting requirements, the facility should consider updating these programs/processes and including the reporting requirements in EHS training. Also, line 9.8 of your RMP should list 40 CFR 1604 - Accidental Release Reporting. The U.S. Chemical Safety and Hazard Investigation Board (CSB) has launched investigations into toxic chemical releases at two facilities in Louisiana during 2023: the release of hydrogen fluoride (HF) and chlorine at a facility in Geismar, LA, in January 2023 and the release of ethylene oxide (EtO) at the a facility in Plaquemine, LA in July 2023. Both incidents were reported to the CSB in accordance with the agency’s Accidental Release Reporting Rule (40 CFR Part 1604). |
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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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