We are all accustomed to labeling our process vessels/tanks with the contents; many of us that operate batch processes even use some specialized labeling and cross-referencing hazard data based on the batch being run. But one item too many of us fail to identify within a vessel is the use of an inert purging/blanketing gas such as Nitrogen. This year a facility had a very serious incident in which a contractor taking measurements in the process area decided he needed to measure the diameter of a manway and in doing do fell unconscious… the culprit? Nitrogen that was blanketing the vessel.
My first question to the business was: “Was the vessel labeled and was the label visible at the point of exposure?”
The answers were NO and NO, but then the debate began… “Does OSHA require it?” My position is ABSOLUTELY OSHA requires it and here is why…
I don’t think many of us will argue that OSHA and State Fire Codes require the contents of the vessel/tank/container to be labeled. We can use a wide array of labels for these containers, such as the GHS Label, HMIS, or NFPA 704 Diamond and of course we are all accustomed to these labels indicating the PRIMARY contents of the container. But where is the “exception” that allows us to not inform the workers of the presence of a serious hazardous material such as an inerting agent?
(emphasis by me)
1910.1200(f)(6) Workplace labeling. Except as provided in paragraphs (f)(7) and (f)(8) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either:
1910.1200(f)(6)(i) The information specified under paragraphs (f)(1)(i) through (v) of this section for labels on shipped containers; or,
1910.1200(f)(6)(ii) Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.
OSHA is most likely going to cite this very standard in this investigation and I for one am not sure of a credible defense. We immediately purchased the signs and had the vessels that are purged/blanketed labeled by the end of the week so I am hoping OSHA will spare the business a large $ fine; but this is a large business in an industry where Nitrogen purges/blankets are a very common matter, but getting the other locations to take similar actions has not been well received.
What say you… Are the vessels that have a Nitrogen purge/blanket REQUIRED to be labeled as such so as to communicate the hazard?