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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:
So here’s a trick question for you IH professionals… When I get my new SDSs, do I have to retain my old MSDS for 30 years?
One standard that OSHA failed to update when they revised 1910.1200 was 1910.1020 - Access to employee exposure and medical records. This standard still uses the term MSDS and does not address my question about the changing of MSDS for the new SDS. Granted, a lot of the exposure info on the new SDS(s) has not changed, but some chemicals did get “classified” differently and may become the focus of some IH monitoring. So my question is:
WARNING - this video shows the ignition of the dust cloud and people within the dust cloud on fire and trying to escape. The sights and sounds of this video ARE VERY GRAPHIC in nature, but shows the hazards of Corn Starch and its ease to ignite.
Corn Starch has one of the lowest MIE's in the Combustible Dust family. We do not yet know the ignition source, but a high wattage concert light bulb or a lit cigarette would be enough to ignite this cloud of corn starch.
As you watch this video, remember the five (5) things that have to be present for a COM DUST incident:
Will our cars soon be miniature PSM/RMP covered processes due to the “mildly flammable” refrigerant they will contain?
No, your car will not be a "covered process" under PSM, but only because it will NOT have 10,000 pounds of this Category 1 Flammable Gas. But this new refrigerant is coming and it will be in your car’s air conditioning very soon! A lot of the literature for this new refrigerant uses phrases like “XXXXXX can be described as being “mildly flammable” as measured by standard methodology”, yet the manufacturer’s SDS looks like this:
Did EPA just issue RMP citations because a facility did not have a Car Seal program? Although they mention Lockout/Tagout in their citation, LOTO is NOT the proper control technique for the "sliding line blind" that was "mistakenly opened by an employee during operation of the unit". LOTO is purely for servicing and maintenance and is not permitted to be used for other purposes (see 1910.147(c)(5)(ii), so a blind that was opened in error during operation of the unit had NOTHING to do with LOTO and everything to do with a car seal program. Here are the details of the incident and the RMP citations: