OSHA issues GDC citation for “hose attached to PRD discharge” ($9K)

This is becoming more common these days; I never encountered it in my career at any of my facilities, as it’s not just a matter of sound engineering. The response I usually get during audits, PHAs, Engineering Code Design reviews is… “show me in the code that says I can’t use a hose on the discharge side of a PRD with a setpoint of X”. And my response is simple… “show me the code which you used to design your PR system and the use of a hose is part of the RAGAGEP”. Codes and Standards cannot include every deviation a person can conjure up; they are meant to draw a box around what is allowed, and anything outside that box is not permitted. In this case, OSHA took issue with the hose as it exposed employees to struck-by hazards…

OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to the hazards of being struck-by fragments of flexible stainless steel metal hose in the event that the hose ruptured:

a) High-Pressure Reactor Room; On or about 12/09/2024, a low-pressure braided metal hose was used on the end of the relief valve of a high-pressure reactor, exposing employees to struck-by hazards.

Source: https://www.osha.gov/ords/imis/establishment.violation_detail?id=1794295.015&citation_id=01001

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