One of the PSM/RMP safe work practices I try and get anyone who I cross paths with to implement on ALL of their hazardous materials (regardless of PSM/RMP applicability) is the Line Break and Equipment Opening procedure and permit process. Too often I learn of incidents in processes where the HHC/EHS was under the PSM/RMP TQ’s so the facility did not have such a program or PTW system for this extremely hazardous task. Although the “process” may not exceed the OSHA/EPA TQ’s, it certainly does not mean the HHC/EHS is any less dangerous while performing certain tasks, such as Line Break and Equipment Opening. In line with my series of post to bring light to this hazardous task and to provide evidence that the HAZMAT does not have to be an HHC or an EHS, here is the latest FATAL posting to OSHA’s database…
At 2:45 p.m. on September 19, 2014, two employees were replacing a valve in a process line that transported 70 percent caustic solution of sodium hydroxide from storage tanks to a loading rack. While they were removing the valve and a stopper plate that had been previously inserted into the line, the employees were sprayed with the caustic solution. The workers suffered chemical burns to their skin and lungs, resulting in their death.
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Violation Summary
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|---|---|---|---|---|---|
| Serious | Willful | Repeat | Other | Total | |
| Initial Violations | 3 | 3 | |||
| Current Violations | 1 | 1 | 2 | ||
| Initial Penalty | $21,000 | $0 | $0 | $0 | $21,000 |
| Current Penalty | $7,000 | $0 | $0 | $4,000 | $11,000 |
| Violation Items | ||||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| # | ID | Type | Standard | Issuance | Abate | Curr$ | Init$ | Contest | LastEvent | |
| 1. | 01001A | Other |
19100132 A – Application. Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact. |
03/19/2015 | 02/23/2016 | $4,000 | $7,000 | 04/13/2015 | F – Formal Settlement | |
| 4. | 01003A | Serious |
19100147 C04 II D – Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures. |
03/19/2015 | 02/23/2016 | $7,000 | $7,000 | 04/13/2015 | F – Formal Settlement | |
