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Yes. When OSHA enacted the PSM requirement, it did so in an effort to eliminate or minimize catastrophic incidents involving highly hazardous chemicals. PSM programs are risk reduction strategies. When implemented correctly, reducing storage inventories of highly hazardous chemicals and isolating stored quantities in distinct facility areas are acceptable risk reduction strategies. Employers at storage facilities may therefore choose to safely alter their storage practices to reduce chemical risks—and fall below PSM applicability criteria—instead of complying with PSM. However, such facilities must still comply with other applicable OSHA standards and section (5)(a)(1) of the OSH Act, the “General Duty Clause” (which requires that employers provide workplaces free from recognized hazards that are likely to cause death or serious physical harm).
CLICK HERE for the recently released DRAFT FAQs
OSHA has published a DRAFT revision of their OSHA 3132, Process Safety Management. This new version is NOT meant to be a replacement for OSHA 3132, but instead meant to be a companion to the original OSHA 3132 specifically for small businesses that may be impacted by the PSM standard. The booklet calls attention to five (5) of the fourteen PSM elements that may have the most impact on small businesses and their process risks...
Cal/OSHA has cited a metal processing company $73,105 for serious safety violations following a March 13, 2016 confined space accident in which a worker was asphyxiated. Cal/OSHA investigators found the company failed to comply with confined space regulations that resulted in the serious illness. On March 13, a supervisor sent an untrained production assistant into a pressure vessel furnace to perform maintenance on it. The assistant did not have an oxygen sensor with him when he descended into the unit, which is only 49 inches wide and 98 inches tall, and was filled with argon gas. Argon is a noble gas that is chemically inert under most conditions and is colorless, odorless, and much heavier than air. When the worker was overcome by the argon gas and collapsed inside the unit, a second worker went in after him and became dizzy and lost consciousness. A third employee then took a nearby fan and blew fresh air into the confined space, which provided air to breathe. The first worker spent four days in a hospital receiving treatment for his illness, and the second employee was transported to the hospital and was treated and released.
The diffuser tank discussion continues and Peter Thomas, P.E. from Resource Compliance, Inc. was kind enough to offer us the following insight as to when a diffuser tank would be required. In most of my postings, I reference the International Fire Code (IFC) and International Mechanical Coden(IMC) quite often, but the Uniform Mechanical Code (UMC) is a code that I have very little experience with and as Peter points out, it is alive and well on the west coast. So it is worth noting that the Uniform Mechanical Code required Diffusion Tanks from 1994-2014 (the requirement removed in 2015 UMC)AND the UMC also required diffuser tanks be of steel construction. Most states utilize the International Mechanical Code, but select western states still use the UMC, or in the case of California the California Mechanical Code which is a derivative of the UMC. Here are some parts of the UMC that Peter provided:
This past week I was having a conversation with my friend and fine PSM professional Brian Chapin @ RCE and our discussion turned to diffuser tanks. Having been involved in several design and install projects over the past several years, getting to know a little something about diffuser tanks comes with the territory. But one of my biggest battles has been the use of "farm tanks" (i.e. plastic tanks) as diffuser tanks. We laughed for a moment and Brian in his usual fashion brought it all home with the question... what RAGAGEP are you using for your diffuser tank(s)?
We just can't make this stuff up. This is NOT staged, this is real life.
WARNING! - Viewer Discretion is Advised! No blood and guts, but the video may be upsetting to some viewers. Worker died from his injuries suffered in this accident caught on CCTV.
Another example of why our Line Break Permitting should cover MORE than just our PSM/RMP covered process(s)!!!
This incident shows us that just because a pipe contains a chemical that may not be included in a PSM/RMP program, it does not mean the level of risk is any less. This explosion was caused by construction workers using a cutting torch to remove old piping from a boiler room and cut into a pocket of residual propane. The workers were removing discontinued piping that was used for fueling the boiler. One of the pipes had residual propane still inside it and when workers began to cut the pipe with a cutting torch, the propane flashed inside the boiler room.
A fire extinguisher is often times looked upon as a safety device and therefore many overlook these devices potential hazards. It is true, they can save lives, but they can also take lives and limbs as was the case in this accident. Back in February, as I reported in the Incident Alerts, two workers were severely injured when a fire extinguisher shell was being used as an air receiver, of which had NO RELIEF VALVE. This happened at a fire protection company. The shell catastrophically failed when they were pressurizing it and the accident claimed BOTH legs of a 35-year-old worker and one leg below the knew of a 23-year-old worker. OSHA has issued their citations...
This case is significant in a number of ways: 1) manufacturer of the equipment put warning signs on their machines pointing out the hazard(s), 2) manufacturer considered the "doors" on their CNC mills and lathes to be "guards", 3) manufacturer installed interlocks on the "doors" (i.e. guards), 4) company bought the machines "used" and many of the interlocks were not operational at the time of purchase, 5) one machine did have a functioning interlock, which was bypassed by tying back it's arm, 6) The VP of the company and the most senior operator felt the machines were safe, 7) neither of these two employees had any training in machine guarding or safety, 8) the company had been cited for machine guarding years earlier and had a serious injury on these machines. OSHA began their inspection based on an employee complaint and issued a willful citation for unguarded CNC lathes and mills. OSHA said the "doors" were guards, based on the manufacturer's operation manual, manufacturer's labels on the machines making reference to them as "guards" and the presence of the interlocks on the doors. The OSHRC agreed and upheld the citation as willful and the full amount. Here is the arguments the company made against OSHA's citations...