During my time in the process industry, we usually had a “caustic scrubber” attached to our PSM/RMP covered process(s). This meant this scrubber was “part of” the covered process. I get a lot of pushback regarding covering “safety critical utilities” that are in place to either PREVENT, PROTECT, or MITIGATE an event from the covered process, but for me, these caustic systems are clearly part of the covered process. In recent years, as a consultant, I have pushed to apply the PSM/RMP Line/Equipment Opening (LEO) Safe Work Practice(s) to other hazardous processes that are NOT officially a PSM/RMP-covered process. Systems such as steam, heat transfer fluids, acids, and bases (such as NAOH) should be included in this SWP. Case in point: LEARN from others’ mistakes.
Employees were removing a flange blank on a caustic liquid pipe that was supposed to be evacuated.
The employees were sprayed with caustic liquid and suffered chemical burns to their faces and eyes.
Two (2) employees, both 50, required hospitalization for treatment, and three (3) others were injured but did not require hospitalization.
| Violations/Penalties | Serious | Willful | Repeat | Other | Unclass | Total |
|---|---|---|---|---|---|---|
| Initial Violations | 9 | 9 | ||||
| Current Violations | 9 | 9 | ||||
| Initial Penalty | $121,446 | $0 | $0 | $0 | $0 | $121,446 |
| Current Penalty | $0 | $0 | $0 | $99,000 | $0 | $99,000 |
| FTA Penalty | $0 | $0 | $0 | $0 | $0 | $0 |
| # | Citation ID | Citaton Type | Standard Cited | Issuance Date | Abatement Due Date | Current Penalty | Initial Penalty | Contest | Latest Event |
|---|---|---|---|---|---|---|---|---|---|
| 1. | 01001 | Other | 19100147 C04 II B | 02/21/2020 | 10/14/2022 | $11,000 | $13,494 | 03/13/2020 | F – Formal Settlement |
| 2. | 01002 | Other | 19100147 C04 II D | 02/21/2020 | 10/14/2022 | $11,000 | $13,494 | 03/13/2020 | F – Formal Settlement |
| 3. | 01003 | Other | 19100147 C06 I | 02/21/2020 | 10/14/2022 | $11,000 | $13,494 | 03/13/2020 | F – Formal Settlement |
| 4. | 01004 | Other | 19100147 C07 I A | 02/21/2020 | 10/14/2022 | $11,000 | $13,494 | 03/13/2020 | F – Formal Settlement |
| 5. | 01005 | Other | 19100147 D04 I | 02/21/2020 | 10/14/2022 | $11,000 | $13,494 | 03/13/2020 | F – Formal Settlement |
| 6. | 01006 | Other | 19100147 D06 | 02/21/2020 | 10/14/2022 | $11,000 | $13,494 | 03/13/2020 | F – Formal Settlement |
| 7. | 01007 | Other | 19100067 C02 I | 02/21/2020 | 10/14/2022 | $11,000 | $13,494 | 03/13/2020 | F – Formal Settlement |
| 8. | 01008 | Other | 19100067 C02 II | 02/21/2020 | 10/14/2022 | $11,000 | $13,494 | 03/13/2020 | F – Formal Settlement |
| 9. | 01009A | Other | 19100120 Q03 III | 02/21/2020 | 10/14/2022 | $11,000 | $13,494 | 03/13/2020 | F – Formal Settlement |
| 10. | 01009B | Other | 19100132 D01 I | 02/21/2020 | 10/14/2022 | $0 | $0 | 03/13/2020 | F – Formal Settlement |
Source: https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1427100.015