ME-OSHA issued two (2) Willfuls and six (6) serious citations to the Fire Department regarding the Sept. 16, 2019 explosion that killed a Captain in a propane explosion. The citations include up to $22,000 in potential fines for the town relating to violations of equipment and training standards. Here is a breakdown of the citations:…...
In a recent FaceBook Group posting, a member asked about using one of the DOT Special Permits that allows DOT containers/cylinders that came with a 15-year service life to have their service extended to 30 years. I wrote about this very issue in September 2019, explaining the pitfalls of using one of these DOT Special…...
The only item remaining in dispute is Item 3b of the citation. Item 3b alleges a violation of 29 CFR 1910.146(c)(4) for failure to develop and implement a permit-required confined space program to control entry of employees into the Fish Bin Chiller Alley at the Seward plant. This item was classified as a serious violation…...
OSHA has updated their COVID Frequently Asked Questions (FAQ) with the addition of three (3) new Q and A’s regarding COVID vaccinations and recordability related to adverse reactions to the vaccine:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
I have written many articles on “scrubbing NH3” in preparation for line breaks/equipment openings or emergency removal from a compromised container and with NH3 the scrubbing media is simply water (H2O). I learned these “scrubbing” methods while working one summer in an internship and the safety pro who hired me was also an MSU graduate…...
Chlorine (Cl2) has a strong warning property: most people can detect Cl2 at approximately 0.002 ppm in air (the official odor threshold per the Agency for Toxic Substances and Disease Registry) and 0.31 ppm in water. However, most data indicate an odor threshold of 0.2-0.4 ppm. In other words, even the most minute leak will…...
This is a common question we get regarding pressure testing and leak testing of process piping. I have written quite a few posts regarding the ASME B31.3 and 31.5 requirements for pressure and leak testing over the years, but this question about holding pressure for 24-hours is one that just will not die. I am…...
Most of my clients who are users of Chlorine (Cl2) use it in vacuum systems where the Cl2 is being injected or inducted into a water flow. In these smaller “processes” it is not unusual to find “tubing” being used vs. hard pipe. It took me years to accept the tubing design model as I…...
I have asked for an official interpretation on this question, but until that arrives I will answer this question as I did for a client this week. Here is the scenario: There is a significant fire in the RMP covered. The fire does NOT cause a release of the EHS, much less get off-site. However,…...
This is a fascinating case, as the OSHRC has upheld this citation, although they significantly reduced the $ and made it “other-than-serious.” But again, I disagree with this case, as the workers appeared to have been protected during the belt change; they did not follow the LOTO procedure, which I believe was “lazily written.” This…...
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 in that employees who performed hydrostatic testing were exposed to struck-by hazards due to the lack of specific testing procedures…...
The Chlorine Institute has updated its instruction booklet for applying an A Kit to 100-LB. & 150-LB. Chlorine Cylinders. Remember, these Instruction Booklets can be downloaded for FREE from their bookstore and if your facility is using 100 or 150 pound Cl2 cylinders, the A Kit is a MUST HAVE and training on the proper…...
