Many THANKS to our NEWEST and CONTINUED "Partners in Safety" for all their support!
"Normal venting" for aboveground tanks
During a recent design review, we encountered some questionable "normal breathing" designs. I have always used the simplest of tests to ensure the tank has ADEQUATE venting during filling and emptying. Although OSHA allows the designer to use API 2000 (1968) or "other accepted standards," the simplest test is that the VENTING capability MUST be as large as the filling or withdrawal connections, but in no case smaller than 1.25". However, unfortunately, designers fail to read ALL of .106(b)(2)(iv), which goes on to state: (emphasis by me) If any tank or pressure vessel has: Membership Content
Condensing water vapor creates a vacuum, destroys tank
"We were doing some cleaning at the end of yesterday. I boiled some water in the HLT to pump through the heat exchanger. At the end of the day, there were 40-50 gal left in our 3bbl HLT. I turned off the heat and went home for the night. The next morning, I came into the brewery to find an imploded HLT. I had clamped the lid on to keep humidity down in the building, and the cooling air/water in the HLT caused the tank to implode." Source: www.probrewer.com Implosion of ISO container during transfer (Vent valve NOT opened)
An ISO container, partly filled with Monoethylene Glycol (MEG), imploded on the back deck of a ship, spilling around two cubic meters (528 gallons) of MEG onto the deck and to sea and causing unrepairable damage to the tank itself. There were no injuries. The tank was a 26-cubic-meter tank containing ten cubic meters (6600 gallons) of MEG. The implosion happened due to a vacuum created inside the tank when the MEG was pumped out into a storage reservoir on the vessel during mobilization. OSHA PSM citations @ Food plant (NH3 & $394K)
OSHA has again found a large food manufacturer with a history of hazardous workplace safety practices in violation of dozens of safety and health hazards. The producer of glass-pack, canned, frozen, refrigerated, freeze-dried, and snack food products under it's brand, as well as other private labels, also operates eight other manufacturing plants, including five in Pennsylvania and one each in Delaware, New Jersey, and Guatemala. In October 2023, CSHOs opened an investigation at the Centre Hall plant in response to a complaint alleging hazards involving the company’s handling of highly hazardous chemicals included in it’s Process Safety Management program. OSHA cited the company for 70 violations, including nine repeat, 51 serious, and 11 other-than-serious violations. The infractions related to numerous Process Safety Management failures, such as lack of training, not correcting equipment deficiencies, failing to document that equipment complied with recognized and generally accepted good engineering practices, and establishing an emergency plan for the entire plant. The agency has assessed the business with $761,876 in penalties. OSHA cited the company for similar violations at its Clayton, Delaware, facility in 2019 and 2021. When do I need to consider desinging and managing an area as a HAZLOC?
One mistake many businesses make is their assumptions about how their flammable liquids will behave once they are outside of their primary containment. I have seen companies spend millions of dollars to classify an area as a HAZLOC when it was not even close to being necessary, and I have seen some PSM businesses claim their 70,000-pound process does not need to be a HAZLOC. One of my advanced Flammable Liquids training course exercises is to help the students visualize the difference in the containers/containment involved in this risk analysis. Standing in the room, I hold up an old sewing thimble and ask, is this enough to make this room a HAZLOC? I then move to an 8-oz cup and ask. We go through the containers (as shown below), and as they work through the numbers in their head, we have great discussions about what we need to consider and how much we should weigh each point of consideration. They realize that the FP, the LEL, and the MIE all play a crucial role in understanding the ignition risks/hazards this flammable liquid or gas poses. Which container would you choose?
Just because you won't be working in a flammable atmopshere, it may still be TOXIC
I will again reference my 30 years of teaching emergency response courses and the surprising lack of hazard awareness so many "certified technicians" lack. The one that get a lot of attention is the relationship between TOXIC and PHYSICAL hazards when the HAZMAT is both toxic and flammable. I have shared many tips over the years, but the following is one that every safety professional should get tattoed onto their forearm: 1% = 10,000 ppm So, let's look at that relationship and think that we measure Lower Explosive Limits (LEL) in percentage and most often use ppm to measure inhalation hazards from vapors and gases. We can begin to see the relationship. This is a key relationship to understand when working in known hazardous atmospheres. We tend to focus on the acute risks when dealing with flammable liquids and gases: ignition of the vapor/gas and the consequences of that event. And YES, we need to be well aware of that hazard. But remember this: Most of the flammables we work around have LELs less than 5%; most are in the 2-3% range. Those percentages translate into the tens of thousands of parts per million (ppm). Take gasoline for example: Why does OSHA use 10% LEL to define a HAZ ATM within a PRCS?
One of the top questions I get via SAFTENG and in my PRCS or Hazardous Atmospheres training courses is... Why did OSHA use 10% LEL to define a hazardous atmosphere? There is an official and logical reason, both of which should be understood. First, the "official" reason: "Banner Safety," it can work, but often does more harm than good
We have all seen them; most of us have used them to deliver a safety message. Let me say this up-front: it is never the banner's fault! A SAFTENG member was reading my posts about "safety banners" and contacted me to discuss their use. They were convinced I was 100% against using "safety banners" after reading my rants against their use. I had to point out that it was not the banner's fault but the lack of management reflecting the messaging on the banner(s). This dual messaging/actions conflict is how the banners can do more harm than good. When I used banners, and I always used banners at my facilities, I followed this time-tested method: PRCS incident kills 7, injures 3 @ Cement Plant (LOTO Failure - 2 Videos)
Seven (7) workers were killed, and three (3) others were injured while conducting periodic maintenance on one of the plant's kilns when the incident occurred. When the workers entered the rotary kiln to start the repair work, the kiln unexpectedly restarted. Replacing the eroded kiln plates is done every 5-7 months and "Things usually go well, but there was an incident this time." It was stated that the kiln started to operate around 35 minutes after the workers entered. The three (3) injured workers were stationed on the roof of the kiln and fell to the ground when it began to rotate.
H2 and O2 explosion learnings (UH explosion resultings in amputation)
Since gas use was integral to the UH accident and since compressed gas cylinders present serious safety issues, several specific examples of improper gas and gas cylinder usage are detailed here. 1. Cylinders in the laboratories adjacent to POST 30 as well as in several laboratories located in different buildings, contained Teflon tape on the CGA connection threads to the cylinder valve |
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
|