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World’s largest automotive supplier, 10 LOTO instance-by-instance citations
An Ohio subsidiary of one of the world’s largest automotive suppliers could have prevented a 26-year-old employee in Franklin from being fatally crushed in October 2023 if the company had provided proper machine guarding. OSHA responded after being informed of the incident and learned the worker, on the job for about a year, was placing cardboard under a machine that bends vehicle exhaust pipes when the incident happened. OSHA issued 10 instance-by-instance citations after finding the company did not properly train employees — including temporary workers under the company’s control — in lockout/tagout procedures. OSHA also issued a machine guarding violation. Investigators determined the employer failed to include detailed steps for lockout/tagout procedures, test its safety procedures annually and guard machines adequately. Based on these alleged violations, the company exposed machine operators to struck-by and caught-between hazards. In 2022, the agency cited the company for similar violations at the same location. The company faces $314,555 in proposed OSHA penalties for its recent infractions. Membership Content
The International Fire Code is an EXCELLENT resource
Are you tired of playing the OSHA Compliance game that requires us to "comply" with standards that are 50 years old? The International Fire Code (IFC) is an excellent resource for taking your hazardous materials handling systems/processes to the next level. The IFC is used or adopted in 42 states, including the District of Columbia, Guam, Puerto Rico, and the U.S. Virgin Islands. This means that most states can enforce the code requirements but rarely do. But this is NOT about complying to make the government happy! It is about advancing our level of safety through enhanced ENGINEERING CONTROLS and DESIGN for our hazardous materials systems and the safety systems we rely on when we have an incident. I have believed in this Code since the start of my career when I worked in a state that enforced its Fire/HAZMAT code, and we got regular inspections by the Authority Having Jurisdiction (AHJ). Hence, I have written or referenced the IFC in over 500 articles on SAFTENG. The ICC offers FREE Access to their codes: CLICK HERE SAFTENG Members can download my training presentations on some of the requirements from this code. Get to know your STKY chemicals (Asphyxiants)
There are two (2) types of Asphyxiants:
These different types of asphyxiants behave differently and cause harm differently.
SIMPLE Asphyxiants displace the 20.8% Oxygen in the atmosphere. These are NOT toxic or poisonous; they are called INERT gases. The most famous SIMPLE Asphyxiant is Nitrogen (N2). It is notoriously renowned as it has killed many workers inside and outside of confined spaces. Since 2020, there have been 14 fatal accidents involving N2 that claimed 26 lives. The most recent claimed Six (6) workers. I have written several articles referencing code requirements when asphyxiants are used in the workplace. Most states (all but six) have adopted some version of the International Fire Code (IFC), which is an excellent baseline for designing systems handling these inert gases and the atmospheric monitoring systems REQUIRED in areas where these asphyxiants are stored, handled, and processed. It takes very little of these gases to create a HAZ ATM (e.g., Oxygen-Deficient). Most of these simple asphyxiants have NO WARNING properties, meaning we can not smell, taste, hear, or feel their presence. A room/space at 20.8% O2 only needs to lose 1.3% of its O2 before we have an IDLH atmosphere. Without proper mechanical exhaust ventilation and/or an atmospheric monitoring system, workers can be overcome quickly. NOTE: another simple asphyxiant gaining popularity without proper safeguards is Carbon Dioxide (CO2). We are seeing Liquid Dewars of CO2 being used in the resturant industry for softdrinl machines as well as its use as a refrigerant in industrial refrigeration systems.
CHEMICAL/SYSTEMIC Asphyxiants work their harm differently. The atmosphere could have adequate Oxygen levels, but once we inhale these chemical/systemic asphyxiants, the hemoglobin in our blood has an affinity for these gases over that of the Oxygen. So these gases attach to our red blood cells/hemoglobin rather than the O2, and we "suffocate" in an adequate supply of O2. Carbon Monoxide is probably the most famous Chemical/Systemic asphyxiant. When we hear of a death by "smoke inhalation," this was a CO-poisoning death. When carbon monoxide is inhaled, it combines with hemoglobin (an iron-protein component of red blood cells), producing carboxyhemoglobin (COHb), which greatly diminishes hemoglobin's oxygen-carrying capacity. Hemoglobin's binding affinity for carbon monoxide is 300 times greater than its affinity for oxygen. (Source: NIOSH) Since 2022, there have been 20 fatal accidents involving CO, claiming 24 lives. Get to know your STKY chemicals (Cl2)
Chlorine is EXTREMELY HAZARDOUS, with an IDLH of 10 ppm and a TLV of 0.5 ppm (just above the odor threshold for most). Chlorine is heavier than air (VD > 2.5), and when released, it forms a greenish-yellow gas with a pungent, irritating odor that follows the terrain at ground level. The mean odor threshold for chlorine lies between 0.2 and 0.4 ppm. Chlorine is a NON-FLAMMABLE gas; however, it is a powerful oxidizing agent, reacting explosively or forming explosive compounds or mixtures with many common chemicals. Chlorine immediately reacts with both organic and inorganic materials it comes into contact with to form chlorides. The primary route of exposure is INHALATION. Chlorine is very volatile, with a Boiling Point of -29°F. So, although it is shipped as a liquidfied gas under pressure, once the primary containment is breached, it will quickly become a GAS. The Vapor Pressure of Cl2 is 6,450 mm hg @ STP. Remember, BP and VP have inverse relationships. As BP goes down, VP goes up, and vice versa. An excellent standard to follow is that water at STP has a VP of 25 mm hg and a BP of 212°F. Cl2 is the opposite: High VP (6,450 mm hg) and Low BP (-29°F).
The Protective Action Distance makes sense when you see this
An image from my HAZMAT courses... People wonder why the ERG Protective Action Distance diagram is shaped like it is. This image validates the model...
NOTE: Cl2 release image is from the Jack Rabbit testing project Human Factors in incident investigations assessment tool
Here is a GREAT "self-assessment" tool, just eight (8) questions, to evaluate your facility's ability to investigate and perform causal analysis properly. Appeals Court sides with Paper Mill over Confined Space incident
This is a crazy case! The mill hired a contractor to build scaffolding inside one of its Chlorine Dioxide (CLO2) tanks. The mill prepped the tank and even performed the initial air sampling of the space. Turned it over to one of the scaffolding contractor employees who would be the attendant for the entry. Three entrants and the attendant were wearing personal Cl2 air monitors. Three scaffolding builders entered the tank. After 30-40 minutes, one of them felt ill and exited the tank. Once outside his personal detector alarmed. Soon after, the other two workers' detectors went into alarm, and they exited the tank. Two entrants were hospitalized for two (2) days; the other two were treated and released. The employee who filed the suit continued to suffer symptoms from chlorine dioxide exposure, including excessive coughing and wheezing. He was diagnosed with bronchiolitis obliterans and upper airway injuries. He sued the mill, the company that made the personal detectors, and the company that supplied the detectors. So far, he has lost his case. This was his appeal, but it did not go well. The paper mill claimed they had no control over the event, even though it was their tank on their property. This post is NOT about limiting liability but about managing PRCS entry hazards. I will note that the meters' manufacturer presented evidence that two of the monitors detected chlorine dioxide limits that would have put them into alarm, but the monitors were switched off less than two minutes later. This happened several times over 24 minutes for one monitor and 33 minutes for the other. As noted above, their final inspection of the monitors before they were sold to the rental company had low alarm settings at 0.10 ppm and high alarm settings at 0.20 ppm. By the time of the incident, the settings had been changed to 0.20 ppm and 0.50 ppm. Safway employees stated that they had not changed the settings. The presumption is that the rental company changed them. Here is all the legal wrangling! OSHA finds Florida contractor ignored federal safety measures that could have prevented welder’s confined space fatality (O2 Deficiency)
As he had many other days, the morning shift welder arrived at 5 a.m. to work on Aug. 28, 2023. Tasked with doing some fabrication work in a 4-foot by 8-foot space in a ship’s hull, the employee began work unaware that fatal suffocation would soon end his life. Less than two hours after entering the ship, a supervisor found the unconscious welder and signaled for help, only to fall unconscious as well. A third employee appeared, alerting EMS and the local Fire Department, who soon transported all three workers to a nearby hospital. Despite emergency treatment, the welder died from a lack of oxygen. The supervisor and the third worker received medical treatment and were released. OSHA CSHOs determined the employer exposed workers to oxygen deficiency by sending the welder into a confined space without testing the air for oxygen content. The presence of welding gas in the space created an oxygen-deficient atmosphere. OSHA investigators found that in addition to a lack of oxygen, the shipbuilder also exposed workers to struck-by and crushing hazards by failing to conduct annual inspections of six cranes. The agency cited the company with four serious violations and has proposed $55,539 in penalties, an amount set by federal statute. The company has contested the findings before the independent Occupational Safety and Health Review Commission. Citations are below... Comparison of Tier II, TRI, and 112(r) Requirements (TCEQ)
The Emergency Planning and Community Right-to-Know Act (EPCRA) requires businesses that store and/or manufacture, process, or use certain chemicals to complete the Tier II (EPCRA 311 and 312) Report and/or the Toxics Release Inventory (EPCRA 313) Report, also called the Form R. Section 112(r) of the Clean Air Act focuses on risk management for accident prevention. While these three (3) programs have similar reporting elements, they have significant differences outlined in the following table. How do you differentiate between an amputation without bone and avulsions?
How do you differentiate between an amputation without bone and avulsions? |
Partner Organizations
I am proud to announce that The Chlorine Institute and SAFTENG have extended our"Partners in Safety" agreement for another year (2024) CI Members, send me an e-mail to request your FREE SAFTENG membership
Member Associations
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