I normally do not share cases that are handled as Expedited Settlement Agreements (ESA) but this one incldued three (3) very common findings during our PSM/RMP audit, so I am sharing this case:
- At the time of the inspection, pipes containing isobutane located at the isobutane tank farm and pipes containing isobutane located in the vault area outside the fencing were not properly labeled to indicate contents and direction of flow. See, e.g., ASME A13.1-2015.
- At the time of the inspection, the primary exit gate from the facility along the northern property boundary did not have panic hardware to allow safe egress. See, e.g., NFPA 58 (2020) § 6.21.4.2(C).
- At the time of the inspection, certain segments ofisobutane piping were not painted, and spacing material was not in place between the piping and piping supports to prevent rust and corrosion, thereby indicating that equipment deficiencies were not being corrected in a safe and timely manner. See, e.g., NFPA 58 (2017) §§ 6.11.3.11 and 6.11.3.14; NFPA 30 (2018),
§ 27.6.4.