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OSHA has cited two companies following an employee’s death at a refining facility. The contractor and the facility collectively face over $106,000 in penalties after the contractor’s employee suffocated to death when he lost his air supply while on the job in a confined space at the facility. OSHA cited the industrial contractor for failing to ensure personnel outside the permit-required...
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With the absence of an OSHA Flammable Gas standard I have been using NFPA 58 since 1994 and it is one of my all time favorite RAGAGEPs. I am always pushing clients to use it for their flammable gases, as well as the IFC Chapter 58, especially when their flammable gases are stored/processes/handled as a Liquidfied Pressurized Gas. This 2020 Edition has some nice revisions and upgrades to...
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The RMP CAFO is very interesting in that the facility stated they were under 10,000 pounds (NH3 TQ) and EPA challenged their numbers, even though the facility had completely pumped down their system and had exact pounds they charged the system with when they started up. So the case is going to court and EPA wrote this CAFO under both the General Duty Clause (in the event the court agrees with the business)...
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I recently received a question from a client about “piping inspection methods for newly installed piping”. It seems that a general contractor was advising the facility that they were “required” to do some “thickness testing” on newly installed piping as part of the installation QA/QC. The PSE asked me “So are we required to take TML’s on newly installed...
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This is an EXCELLENT LOI from OSHA that covers three (3) IMPORTANT aspect of PSM applicability:
Co-Location of smaller containers of flammables that could be impacted by a single event (i.e. fire)
Once a process is PSM covered it remains such UNTIL such time the employer puts in place a means to LIMIT the quantity of the HHC below it’s TQ within the process, and
how compliance with...
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Scenario:
An employee experienced an injury when sharpening a personal pocket-knife while sitting in a company owned-truck parked in the employer’s parking lot. The employee lacerated the palm of his hand and was treated with seven sutures, and the employee returned to work immediately with no restrictions. You state that because the employee was on his lunch break at the time of the injury,...
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Way back in 1994 when I was implementing my first FRC program there was a great debate on the options that would be made available to operators, maintenance, engineering, EHS, and QA/QC personnel who perform work within a HAZLOC. This debate was of course driven by costs vs. risks and luckily I was working for a Plant Manager that put safety above all else. But the battle was not fully won, as the...
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The car manufacturers have begun using a new refrigerant for our cars and trucks air conditioning systems. This new refrigerant, HFO-1234yf, is received by truck, stored as a liquified (pressurized) gas, and dispensed into the vehicles A/C unit. The piping associated with this storage and transfer of this refrigerant must meet…
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We see a lot about Corrosion Under Insulation (CUI) as it relates to piping, but we can not forget that the same failure mode can occur on vessels as well. API 510 spells out some ranges as to when we MUST consider the need for a CUI inspection on our vessel(s).
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Sorry for a lack of posts these last couple of weeks, they have been crazy with travel and work. But I wanted to follow-up on a lot of questions and comments I got regarding my “Internal inspections… of my pressure vessel??? We don’t need no internal inspections” post a few weeks back. If your engineers/management is telling you that the vessel does not need (or...
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On June 3, 2019, a railcar catatrophically failed when incompatible materials stored inside the car reacted and approximately 20,000 gallons of liquid waste derived fuel – fuel derived from hazardous waste – spewed from the railcar for 34 seconds. The eruption sent waste fuel several hundred feet into the air and ripped the manway hatch from the railcar. The hatch came to rest approximately 370 yards...
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Sometimes the OSHA “Request for public comments” postings contains some really good insights as to the documentation aspect to OSHA compliance. This week’s posting does a nice job of explaining all that is required to document our PPE Hazard Assessments:
(emphasis by me, but 100% OSHA wording)
Paragraph 1910.132(d)(1) and the Personal Fall Protection standard REQUIRE…...
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