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At approximately 7:00 p.m. on November 15, 2006, Employee #1 was a process operator at the Chlorine Liquefaction Unit, Block A-19. He was preparing to bleed off chlorine on a process line, to clear the line for maintenance work. The valve handle indicated that it was in a closed position. Employee #1 opened the cap to the bleed valve to insert a tube to clear the chlorine. However, the bleed valve was not completely closed, and the pressure on the chlorine line caused the cap to blow off, releasing chlorine. Employee #1 was exposed to the inhalation hazard of chlorine gas when his airline became caught on a nearby pipe and his mask was pulled away. He continued to work until his shift was over. He went to a coworker's home after leaving the plant because he was too tired to go home. Employee #1 was hospitalized approximately one hour later. He was pronounced dead at 10:00 a.m. on November 16, 2006.
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is a look at OSHA's PRCS activity in 2016 (October 2015 - September 2016). As you can see, OSHA did 192 PRCS inspections (↓) and issued 435 citations (↓) for a total of $1,285,302 in fines (↓). 2015 numbers were 206 inspections; 545 citations; and $1,435,301. This is the SETTLED amount and NOT the initial citations. Here is a quick breakdown of activity:
Here is a look at OSHA's Process Safety Management (PSM) activity in 2016 (October 2015 - September 2016). As you can see, OSHA did 140 PSM inspections (↑) and issued 669 citations (↑) for a total of $2,819,533 in fines (↑). 2015 numbers were 109 PSM inpsections; 477 citations; and $2,344,741. This is the SETTLED amount and NOT the initial citations. Here is a quick breakdown of activity:
Here is a look at OSHA's Lockout/Tagout (LOTO) activity in 2016 (October 2015 - September 2016). As you can see, OSHA did 1,780 LOTO inspections (↓) and issued 3,235 citations (↑) for a total of $16,611,253 in fines (↑). 2015 numbers were 1,796 LOTO inpsections; 3,139 citations; and $9,013,808.
This is the SETTLED amount and NOT the initial citations. Here is a quick breakdown of activity:
emphasis added by me and professionally speaking, this LOI is just "crazy talk" and why OSHA LOTO minimums should be viewed as just that... the ABSOLUTE MINIMUM! In this LOI, OSHA has established that using a "zip-tie" in the manner in which you would apply a lockout lock to an electrical disconnect would meet the "tag-plus" requirement under a "tag-out" program! So basically, if you were to hang a Tagout tag with a zip tie and run the zip tie through the disconnect handle so that the handle is secured in the OPEN/OFF position, this would suffice in meeting the "additional means" requirement under the tagout provisions. So today class, we have learned from OSHA that a zip tie is equal to a lock - NOT!, NO WAY!, NEVER! I swear in Question #2 that OSHA is accepting the mere placing of a zip tie on the "closed electrical panel box after placing the control switch in the off position and performing verification" as an "additional means of demonstrating full employee protection under the standard". So the zip-tie is merely hanging a tagout tag from the box/cover and is not even through the handle and this meets compliance?!?!?! But again, meeting OSHA minimum in a life-critical procedure is NEVER a good idea! Here's the scenario and questions with OSHA's response... you may want to sit down before reading further!
Scenario: Maintenance and servicing activities are required and the plant owner hires a contractor to perform the work using ONLY a tagout program, although the devices ARE CAPABLE of being locked out. The electrical disconnect (i.e. control switch) [SAFTENG comment - the disconnect is the ISOLATION DEVICE - NOT a control device] is placed in the OPEN/OFF position, verification is performed, and the panel is closed and secured with a plastic zip tie at the point where a lock would be used. This is all done by a plant representative. At this point, the plant considers the equipment safe for contractors to sign onto the plant's clearance and to begin maintenance or servicing activities.
Union Pacific railroad worker killed by train near Wallula (worker, 54, was killed by a train at 5:30 a.m. along the railroad track - no other details)
CRUSHED Worker killed in apparent accident at Manning Supply (worker, 57, was crushed and killed while handling large panel doors on the company’s lot -several workers were transferring building materials, including the doors, from one semi-trailer to another - during the process, several doors shifted, striking the victim and pinning him against the wall of the trailer)
ELECTRICAL 1 electric worker killed, 1 hurt during East Texas repairs (one electric worker has died and another was hurt after being shocked while repairing downed power lines after a traffic accident - two contract workers were dispatched to do repairs when both were accidentally shocked - the victims were transported to a hospital, where one was declared dead and the other was treated for serious injuries)
FORKLIFT FATALITY Worker killed in forklift mishap at FDNY parts depot (worker was killed when he became pinned between a forklift and a delivery truck when he put the forklift in neutral and placed it next to his van - when he left the heavy machinery to retrieve something from the van, the forklift somehow started rolling, crushing him between the van and the forklift - cops responding to the scene at 12:35 p.m. found the man unconscious and unresponsive - EMS brought him to a Hospital, where he was pronounced dead)
If you've ever driven on an industrial plant site you most likely have noticed the speed limits on these sites is rather low, say 10 mph. However, some sites we have visited we have seen speed limits up in the 20 mph range. Now if there is no critical infrastructure in the area, we just look the other way and keep our mouths shut. But if we see speed limits over 10 mph right next to critical infrastructure such as pipe bridges, storage vessels, etc. we make a point to discuss an engineering concern.
With last weeks tragic accident in my old stomping grounds of DeRidder, LA I am reminded of OSHA's laguage in 1910.252. I know of no other standard that has such "matter of fact" style language. In the standard, OSHA uses the phrase "absolutely certain" in regards to ensuring the "container" is gas/vapor free. In fact the standard goes as far as requiring the "container" be free of "any substances such as grease, tars, acids, or other materials which when subjected to heat, might produce flammable or toxic vapors". In a paper mill a "foul codensate" tank fits these definitions darn near perfectly. We will have to wait until all the investigations are completed to know more, but in reality WELDING ON CONTAINERS has some ABSOLUTE REQUIREMENTS for a good reason. May the three contractors who died in this accident Rest In Peace and may God be with their loved ones.
1910.252(a)(3)(i) Used containers. No welding, cutting, or other hot work shall be performed on used drums, barrels, tanks or other containers until they have been cleaned so thoroughly as to make absolutely certain that there are no flammable materials present or any substances such as greases, tars, acids, or other materials which when subjected to heat, might produce flammable or toxic vapors. Any pipe lines or connections to the drum or vessel shall be disconnected or blanked.