WARNING! Viewer Discretion is advised, video could be upsetting to some. This LOTO fatality is from 2012, but it is so telling that it is worth sharing again! This is a true and actual event at a bottling plant and involved a temp-worker cleaning broken bottles from UNDER the palletizer WITHOUT the aid of LOTO […]
Respondent operates a river barge terminal, which stores anhydrous ammonia and blends fertilizers for sale to farmers and cooperatives (NAICS code: 42459; Other Farm Product Raw Material Merchant Wholesaler). Anhydrous ammonia is received via barge and rail, stored, and distributed for both direct application and for blending into mixed-grade fertilizers for crop production nutrients. Approximately,
Respondent operates a chemical manufacturing plant which has more than 2,500 pounds of chlorine in a process, making the process a RMProgram level 3 covered chemical manufacturing process, which stores or otherwise uses chlorine in an amount exceeding its applicable threshold of2,500 pounds. On November 10, 2015, the EPA conducted an onsite inspection of the
This is another incident involving hot-gas defrost and liquid hammering effect causing a large diameter pipe to fail and releasing 183 pounds of NH3. This failure actually occurred inside the building (vs the 2010 Mobile, AL hammering release occurred on the roof of the building) and had far-reaching and serious consequences. Respondent owns and operates
This week we saw a construction vehicle strike a fill valve of an underground propane tank. The valve was not only unprotected, it was actually camouflaged by a large plastic trash can that sat over top of it. The valves for the 1000 gallon tank were struck by a construction vehicle which led to an active and
Back in 2015 I wrote about changing the “service” of a pressure vessel and all that should be considered in this change. Late last year my team and I ran across a very common error in “changing the service”, albeit the change was an actual change of location. Here’s what happened…
The transfer of Class IA liquids from polyethylene drums and containers may be safety accomplished and is deemed to comply with the intent of the standards at 29 CFR 1910.106(e)(6)(ii) and (h)(7)(i)(b) when: A polyethylene drum is equipped with an approved metallic suction pump and draw tube for taking liquid through the top of the
OSHA does not have any provisions that require the emergency relief devices on PORTABLE TANKS to discharge to the outside of buildings. However, if portable tanks are part of a PSM-covered process, at a minimum, the employer would be required to IDENTIFY, EVALUATE, AND CONTROL [§1910.119(e)(1)] the hazard of discharging flammable and combustible materials through
OSHA bases their position on which section of 1910.106 would be applicable; if the plant is an industrial (covered under 1910.106 (e)) or a processing plant (covered under 1910.106(h)). If the operation is an incidental activity covered by §1910.106(e)(2), paragraph §1910.106(e)(2)(iv)(d) allows transfer of flammable or combustible liquids into vessels, containers, and portable tanks within
OSHA’s says No; 1910.106(e)(2)(iii) does NOT require the exclusive use of fresh air for ventilation purposes. OSHA states that 1910.106(e)(2)(iii) is a performance requirement and does NOT explicitly require the introduction of fresh air to meet the performance requirements of the OSHA standard. OSHA, under §1910.106(e)(2)(iii), expects employers to provide adequate ventilation to maintain concentrations
We are no longer surprised when we come across a “process” which is not a PSM-covered process because the facility has managed the quantity of their HHC below OSHA’s threshold. However, from a risk perspective, having 9,975 pounds of an HHC versus having 10,000 pounds does not lessen our process or personnel risks, but that
Respondent produces meat and protein products for sale by third-party customers. As part of this process, Respondent uses anhydrous ammonia in a chill tank to prepare and preserve the products. Ammonia is a regulated substance listed in Table 1 to 40 CFR § 68.130. On the evening of January 15, 2016, after the Facility had
