OSHA Compliance

Line Break Gone Bad (toxic/corrosive liquid containing aniline, formalin, and HCL)

On September 22, 2022, at approximately 9:00 a.m., a liquid mixture comprised of aniline, formalin, and hydrochloric acid was accidentally released, seriously injuring one contractor at a chemical manufacturing facility in Geismar, Louisiana. On September 20, 2022, two days before the incident, an off-site power outage caused an immediate loss of process flow into the…...

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Response to “fugitive emission” of Cl2 leak goes catastrophically bad (CUI)

On October 1, 2020, at approximately 9:00 a.m., approximately 554 pounds of chlorine gas were accidentally released. Exposure to the toxic chlorine vapors seriously injured one employee. At the time of the incident, four (4) workers (two unit employees and two contractors) were trying to stop a chlorine leak (described as a fugitive emission) from…...

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Line Break Gone Bad (Silicon tetrachloride)

At the time of the event, contract workers were disassembling a 2-inch flange to remove a blind (a solid metal plate used to isolate equipment) before reinstalling a section of piping that had been removed and cleaned. This type of equipment opening is commonly referred to as a “line opening” or “performing a line break.”…...

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Recordability of workplace injuries resulting from personal rechargeable lithium-ion batteries (OSHA LOI)

Scenario: Employees bring rechargeable lithium-ion batteries from home to the workplace for use in e-cigarettes, which are not used in any equipment or devices related to their work duties. You also state that, in this scenario, the battery terminals are unprotected and the employee or employees improperly carry these batteries in their pants pocket, a…...

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Electrical Safety is cheap when compared to a $1.5 loss

ATF investigators determined that the fire originated in the upper level of the engine room, portside aft. A paint locker was located in the area of origin, with various combustible materials stored both inside and outside the locker. Interviews with the vessel’s engineer revealed that a boot warmer had been plugged into an extension cord…...

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When the room design proves the PSV is not “discharging to a safe location”

This is a real-life story of Elimination vs. Engineering Control We see some odd designs in our work around the world, but recently we came across a setup that defied any logic for a relief valve design basis. For some reason, the OEM and Installer of this process equipment wanted it enclosed for “efficiency”; however,…...

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Ai agrees with me on “pressure decay” NOT being an acceptable leak test method

I fight this battle every year! It’s usually a learning experience for people unfamiliar with chemical processing and ASME B31.3. But I do my best to ensure they understand how the 10-minute Pressure Test is done, and then how the Leak Testing is done. So today I decided I need to “test” my practice that…...

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CSB’s Safety Bulletin – REMOVAL OF HAZARDOUS MATERIAL FROM PIPING SYSTEMS (2004)

Chemical and refinery facility personnel open piping and equipment to perform routine maintenance, add/replace components, or modify pipe routing. The piping may contain hazardous material, such as flammable hydrocarbons, toxic chemicals, or thermally reactive chemicals. Safe work practices dictate the removal or mechanical isolation of hazardous material from piping and equipment (e.g., using valves or…...

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OPEN ended piping in Hazardous Materials process

In an earlier post tonight, I shared an OSHA Hazard Bulletin from 1993 titled: Chemical Exposures from Industrial Valve and Piping Systems. In that Bulletin OSHA, talks about the hazards and accidents related to workers opening processes. But there is another serious error we see often… Open Ended Piping. This is a serious NO-NO in…...

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Sampling from a “Live Process”

The risks in sampling activities can be off the charts without engineering controls, Administrative Controls, and PPE. This post shares my sampling system. I learned this the hard way, and I hope some will take this advice and reduce the risks when we ask operators to collect a sample from a “live process”. As I…...

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Lack of ventilation, fixed gas detection, draining hazardous materials SOP, and personal gas monitor leads to asphyxiation fatality

During the morning of February 24, 2023, an unknown amount of hydrocarbons and hydrogen sulfide were released, fatally injuring an employee inside an enclosed building at an oil and gas facility in North Dakota. The hydrocarbons and hydrogen sulfide displaced the oxygen in the building, and the employee asphyxiated in the oxygen-deficient atmosphere. The employee…...

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Contractor’s Scissor Lift causes 22,000 pound fatal NH3 release

On December 19, 2022, at approximately 11:10 a.m., an accidental release of 22,000 pounds of anhydrous ammonia occurred from the NH3 refrigeration process at a food processing facility in Norwood, Massachusetts. Exposure to the toxic ammonia vapor fatally injured one contract worker and seriously injured another contract worker. In addition, the release caused about $4…...

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