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One of the top items from our process safety audits, PHAs, assessments, etc. is the lack of vehicle protection around critical equipment/infastructure. Number one target in process plants is overhead piping! It seems no matter how high we put it, it will get hit. Already this year we were told that the pipe bridge over the main raod was "high enough" and that no height signs or protection systems were needed. Months later the safety manager sent me a picture of a dump truck stuck under that same pipe bridge with its bed fully up. The accident cost them a reportable release, a visit by EPA (still awaiting the damage assessment from that visit) and around $300K in damages, not counting the lost production! Case in point... keep in mind this vehicle was traveling at a higher rate of speed than those in our plants, but the force is great even at 10-15 mph.
One of the top questions I receive is asking about how NFPA 704 ratings play into the application to OSHA's Process Safety Management standard and EPA's Risk Management Plan rule. I hope to clarify any confusion this NFPA 704 application may be causing, as YES - the NFPA 704 does have a role in determining if certain MIXTURES fall under the RMP rule. However, this ONLY applies to certain FLAMMABLE MIXTURES and ONLY is used in EPA's RMP rule - NOT in OSHA's PSM application. Let me explain ...
OSHA has started its Small Business Advocacy Review Panel in order to get feedback on several potential revisions to OSHA's Process Safety Management Program (PSM) standard. The modernization topics OSHA is considering stem from industry best practices, inspection history, stakeholder comments received in response to OSHA's 2013 Request for Information and lessons learned from accidents involving highly hazardous chemicals. Topics to be considered by the Small Business Panel include:
KMCL has noted that OSHA has been very aggressive in its enforcement efforts and in seeking large penalties over the last several months. As described below, the initiatives the agency has recently announced signal that this intensity will continue to ratchet up over the coming months and likely beyond. As a result, employers should consider evaluating whether they are prepared for an OSHA inspection; the days of the proverbial slap on the wrist appear to be over.
The Environmental Protection Agency (EPA) is amending its hazard categories in the regulations (40 CFR part 370) for reporting under Sections 311 and 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA) due to the changes in the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS). OSHA's HCS was revised in 2012 to conform to the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Under the revised HCS, chemical manufacturers and importers are required to evaluate their chemicals according to the new criteria adopted from GHS to ensure that they are classified and labeled appropriately. Manufacturers and importers are also required to develop standardized Safety Data Sheets (formerly known as "Material Safety Data Sheets/MSDS") and distribute them to downstream users of their chemicals. These changes to OSHA's HCS affect the reporting requirements under sections 311 and 312 of EPCRA.
This week OSHA issued a willful violation for Lockout/Tagout (LOTO) deficiencies involving a spray dryer absorber (SDA) at a power generation plant. What is shocking is the fact that a 46 year old worker lost four (4) fingers on his right hand in the December 2015 accident and during the course of its investigation into the December 2015 accident, OSHA found that multi-finger amputations also occurred on this SAME SDA in August 2011 and October 2012. Folks this happened, not at a "mom and pop shop", but rather a power company with generating capacity of 26 GW, capable of supplying more than 21 million households, operates 35 Power Plants across 8 states, has 830,000 retail customers, residential customers and 23,000 commercial, industrial and municipal customers, and Annual Revenues of over $5 billion! (Source) And here we sit in 2016 not able to comply with one of the most fundamental OSHA standards that is now over 25 years old and three (3) workers have suffered debilitating - life changing injuries.
Here is a look at the citations:
It appears OSHA is getting serious about 1910.106(e)(2)(ii)(b)...
1910.106(e)(2)(ii) "Containers." flammable liquids shall be stored in tanks or closed containers.
1910.106(e)(2)(ii)(a) Except as provided in subdivisions (b) and (c) of this subdivision, all storage shall comply with paragraph (d) (3) or (4) of this section.
1910.106(e)(2)(ii)(b) The quantity of liquid that may be located outside of an inside storage room or storage cabinet in a building or in any one fire area of a building shall not exceed: