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Between 1996 and 2008 it is estimated that there have been 173 loss of primary containment (LOPC) incidents reported in RIDDOR that can be attributable to ageing plant. This represents 5.5% of all loss of containment events. The limited information provided in RIDDOR about the underlying causes means that it is difficult to identify which events may be age related: the actual number could be much higher than that quoted here. Across Europe, between 1980 and 2006, it is estimated that there have been 96 incidents reported in the MARS database relating to major accident potential loss of containment which are estimated to be due to ageing plant. This represents 28% of all reported ‘major accident’ loss of containment events in the MARS database and equates to an overall loss of 11 lives ,183 injuries and over 170 Million € of economic loss. As the MARS data provides the more detailed and comprehensive insight into the incidents and causal factors and is specifically related to potential major accident hazard events, it is considered that this represents a more realistic indication of the extent and severity of ageing plant and its contribution to major accidents. This leads to the conclusion that ageing plant is a significant issue.
Comparing OSHA’s Confined Spaces in Construction standard (1926.1201-.1212) to the General Industry Standard (1910.146)
I do not work on construction sites so I have not been following the roll-out of OSHA Confined Space standard for the Construction Industry (1926.1200) all that closely. But my phone has not stopped ringing with clients who have received a ton of advertising about how this “new OSHA rule will impact you”. Some of this literature is just disgusting in how it misleads an unsuspecting manager who wants to do the right thing. But as I began to research some of these claims I did take notice that this new CS standard for construction can be a glimpse into OSHA’s 2nd attempt at writing a CS standard and some of the new definitions and requirements should be included in our general industry program(s).
Let’s look at some of these requirements:
We came across this dosey during one of our projects. It is exactly what you think it is... operators tired of having an alarm go off. They wrote work order after work order to have the set point changed and each one was denied. They then wrote a work order to have this switch installed so they could turn OFF the alarm. I kid you not!
EPA RMP General Duty Clause citation @ oil and gas facility (Flammables; $30K - Forklift struck process piping causing N.G. release)
At the facility, the respondent primarily engages in the production of oil and gas from underground reservoirs. The operation at the Facility includes various piping, heater treaters, and a high-low pressure separator vessel used for separating well fluids into gaseous and liquid components. Natural gas is a highly flammable gaseous hydrocarbon mixture containing methane, ethane, propane and butane, which are regulated substances listed in table 3 of 40 CFR 68.130. Natural gas itself' is an extremely hazardous substance that may ignite, Flashback or explode when exposed to a source of ignition. At the Facility, respondent produces, processes, handles, or stores substances listed in, or pursuant to, CAA 112(r)(33 or other extremely hazardous substances identified as such due to toxicity, reactivity, flammability, volatility, or corrosivity. The release of natural gas at the Facility on July 26, 2014, constituted an "accidental release" as that term is defined by section 112(r)(2)(A) of the CAA. Respondent failed to design and maintain a safe facility and did not take such necessary steps to prevent accidental releases by not ensuring safety during forklift operations in and around piping containing explosive and flammable liquids and gases. Respondent's failure constitutes a violation of the general duly clause in section 112(r)(1) of the CAA. EPA and respondent agree that an appropriate penalty to settle this matter is $30,000. CLICK HERE for source
OSHA initiated a PSM inspection under the agency's Site Specific Targeting program for industries with high injury and illness rates and its Process Safety Managed Covered Chemical Facilities National Emphasis Program. Eight of the 15 serious violations are related to the Process Safety Management Program for the maintenance and operation of the Anhydrous Ammonia refrigerant system to prevent potentially catastrophic releases. The violations include failing to inspect and test equipment intended to control and contain ammonia; failing to maintain process equipment in an acceptable working order; and not ensuring that process information is up to date and accurate. The company was also cited for failing to provide emergency eyewash, not having an audiometric testing program, and improper chemical storage. Proposed penalties are $76,500. Here is a breakdown of the citations:
NOTE: Anyone in the refrigeration industry following “IIRA/ASME-15”? LOL, there is one citation that will be thrown-out! There are a few other "odd" citations such as Citation 1 Item 1 for not having a exhaust fan switch outside the engineroom was a "general duty clause" citation????
OSHA has announced their Information Collection Activities; Submission for OMB Review; Comment Request; Permit-Required Confined Spaces in General Industry Standard. Some of these announcements have some interesting tid-bits in them. This PRCS announcement listed all the documentation one would need to fully comply with 1910.146. Most of us could list many of these items, but some may not come to mind until you read them in OSHA's posting...
About 3:30 a.m. on June 4, 1999, a Quality Carriers, Inc., truckdriver arrived at the Whitehall Leather Company1 tannery in Whitehall, Michigan, to deliver a load of sodium hydrosulfide solution. The truckdriver had never been to the plant before. Upon arrival, he asked a tannery employee for assistance. The employee called the shift supervisor, who met the driver at the plant employee's work station. The shift supervisor stated that the only chemical shipment he had previously received on the third shift was "pickle acid" (ferrous sulfate).2 He said he had not been told to expect the delivery of another chemical on the shift,3 so he assumed this load was also pickle acid. The supervisor stated that because the driver did not know the plant's layout and was unfamiliar with where to unload his cargo, he walked the driver through the plant and out to the pickle acid transfer area. The supervisor did not verify what chemical was being delivered. The shipping documents identified the cargo as sodium hydrosulfide solution. The shift supervisor showed the driver the ferrous sulfate connection (the only working transfer connection at that location) so he could deliver his product. (See figure 1.) The shift supervisor then unlocked a gate to allow the driver to bring his vehicle onto the plant property. The driver asked the supervisor to sign the shipping documents so he would not have to find the supervisor after the transfer was completed. According to the supervisor, he signed the paperwork without reading it and left the area. The signature block that the supervisor signed stated the following: "I have checked the documents for this shipment and verify that there is adequate storage room to receive this shipment and connection has been made to the proper storage facility."
About 7:15 a.m. eastern standard time on November 19, 1998, a cargo tank truck arrived at a Automotobile Plant in Louisville, Kentucky, to deliver a liquid mixture of nickel nitrate and phosphoric acid (a solution designated CHEMFOS 700 by the shipper). A plant employee told the truckdriver to park his vehicle next to the chemical transfer station outside the bulk storage building and wait for a pipefitter to assist him in unloading the chemical. According to testimony, a short time later, the pipefitter arrived at the transfer station and told the driver that he would assist him in unloading the cargo tank. The pipefitter opened an access panel containing six identical pipe connections. Each pipe connection served a different storage tank, and each connection was marked with the plant's designation for the chemical stored in that tank. The driver told the pipefitter that he was delivering CHEMFOS 700 and then went to the driver's side of the cargo tank and took out a cargo transfer hose. The pipefitter connected one end of the hose to one of the transfer couplers, while the driver connected the other end of the hose to the cargo tank's discharge fitting. Unknown to the pipefitter or the truckdriver, the pipefitter had inadvertently attached the hose to the coupler marked "CHEMFOS LIQ. ADD" instead of to the adjacent coupler marked "CHEMFOS 700." The storage tank served by the coupler marked "CHEMFOS LIQ. ADD" contained sodium nitrite solution. The driver climbed to the top of the cargo tank, connected a compressed air hose to a fitting, and pressurized the cargo tank. The driver and the pipefitter then reviewed the cargo manifest and bill of lading. The pipefitter signed three different certifications on the cargo manifest, one of which certified that the transfer hose was "connected to the proper receiving line." The pipefitter asked the driver how long it would take to unload the contents of the cargo tank, and the driver told him the transfer would take about 30 to 40 minutes. The pipefitter then left the loading area, leaving the driver to complete the unloading by himself. About 8:15 a.m., after the air pressure was built up in the cargo tank, the truckdriver started the transfer. When the nickel nitrate and phosphoric acid solution from the truck mixed with the sodium nitrite solution in the storage tank, a chemical reaction occurred that produced toxic gases of nitric oxide and nitrogen dioxide. The driver stated that about 10 minutes after he started the transfer, he saw an orange cloud coming from the bulk storage building. He said he closed the internal valve of the cargo tank to stop the transfer of cargo and waited for someone to come out of the building. After several minutes, the pipefitter ran out of the building and gestured for the driver to stop the unloading process. Here is the full NTSB investigation: