We have discussed “pressure testing” and the hazards associated with these required tests many times. This is an example of what can go wrong when doing these tests with a compressed gas vs. hydrostatically! A mechanical contractor was increasing the pressure into the 4-inch compressed air line from approximately 125psi to the TEST PRESSURE of…...
OSHA has dined a Delaware Rail Car Tank Cleaning And Repair Facility $371,276 for Safety and Health Hazards. This same company, different location, was cited last year after a PRCS fatality inside a Rail Car (PRCS fatality cleaning a railcar (Oxygen Deficient and $551K): Membership Content). This inspection was initiated due to a complaint, but surely…...
Earlier today I posted a recent OSHA citation where a facility was cited for not having procedures regarding the means to isolate and verify ZES for pneumatic energy sources (i.e. plant air). For some reason, on nearly all of my LOTO projects I find that air sources are a bastardized source of energy when it…...
This OSHA citation involves items other than LOTO. Still, the LOTO citations caught my eye precisely because the equipment-specific procedures did NOT state how pneumatic sources (e.g., air) were to be verified at a Zero Energy State (ZES). The means to verify a ZES is a critical step in LOTO, and far too often, the…...
A lot of older plants in the USA use their water piping as their main ground for a lot of purposes. In one such plant, the grounding connections for the flammable liquid transfers were tied into the water piping. One day a water pipe failed and caused quite a bit of damage; the price to…...
A number of years ago a former client decided that process safety was not worth the effort and wanted to get their process below the 10,000 pounds TQ for their LPG. They hired a local architect/engineering firm that had no experience with the storage, handling, and processing of LPGs. This “architect/engineering firm” advised the facility…...
The only OSHA standards that make mention of the phrase “Double Block and Bleed” (DB&B) are its Permit-Required Confined Space (PRCS) standards. In both 1910.146(b) and 1926.1203, OSHA defines a DB&B as: the closure of a line, duct, or pipe by closing and locking or tagging two in-line valves and by opening and locking or…...
It seems every generation is destined to have its own structure fire tragedy; ours being the Station Nightclub fire in West Warwick, Rhode Island in 2003. In less than 30 minutes, 100 people lost their lives that night (February 20, 2003). I had just started consulting and I can remember it well as almost all…...
Since I began consulting I learned of something I thought I would never see… an ASME pressure vessel without a pressure relief device (PRD). Typically when I have come across one of these vessels I have gotten the “grandfather” or “its too small” justification. So let’s discuss these two items and see if they are…...
This case is going before the full review commission, but below are the ALJ’s view on the citations. This case is what we (the safety profession) warn employers what can happen with a lack of proper oversight. The citations are about as basic as they come and the CSHO nailed the inspection with great documentation…...
I will offer my 1-day PRCS training class for SAFETY PROFESSIONALS for FREE as long as a company steps up to sponsor the course. Sponsoring a course means you provide the training accommodations and lunch; SAFTENG provides the training and materials. The sponsor gets 3-5 seats in the class in return for sponsoring the course…....
The department is initiating rulemaking to implement the advanced safety training requirements for High Hazard Facilities. Chapter 49.80 RCW, enacted in 2019, requires owners of petroleum refining or petrochemical manufacturing facilities to use a skilled and trained workforce when contracting for construction, alteration, demolition, installation, repair, or maintenance work. By January 1, 2022, all workers…...
