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Incidental Release or Uncontrolled Release of NH3 - What say you?
Safety Info Posts - Emergency Response
Written by Bryan Haywood   
Friday, 19 December 2014 00:49

So you have to make the call... Is this an incidental release or would this release rise to the level of sounding the alarm, evacuating the engineroom - thus making this an emergency response?

Incidental Release or Emergency Response?
pollcode.com free polls

Last Updated on Friday, 19 December 2014 00:54
 
Another MI learning opportunity with regard to corrosion in piping
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Thursday, 18 December 2014 15:06

six-inch-reactor-effluent-line-refinery-2011-investigationThis is another lesson’s learned regarding piping and its mechanical integrity. On October 6, 2011, an explosion and subsequent fire occurred in the Middle Distillate Unifiner (MDU) area at a Canadian refinery and injured 52 workers. This third party analysis of the piping involved and its failure mode paint an ugly picture of how improper MI management can lead one to misunderstand the true condition of their piping. The incident also points out that changes to processing conditions can have a long-term impact on the MI of piping (and vessels as well). In this case, a change in process conditions created more water vapor in the pipe that failed and this factor lead to increased corrosion rates; however, the refinery did not recognize this and therefore did NOT increase their inspection/testing frequencies on the piping. EVERYONE who participates in process safety should take the time to read this report and ask the question... "Could this happen here?" Here is the report summary and link to the full report...

Last Updated on Thursday, 18 December 2014 15:25
 
47 incidents & 2 updates (12/18/14)
Safety Info Posts - Incident Alerts
Written by Bryan Haywood   
Thursday, 18 December 2014 13:16
 
OSHA PSM Citations @ nail polish manufacturer (Flammables & $139K)
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Monday, 15 December 2014 19:58

OSHA found plant workers and temporary workers employed by two staffing agencies were exposed to hazards and other dangerous safety and health violations at the plant. The inspection resulted in 30 OSHA citations against the nail polish manufacturer and staffing agencies. Proposed penalties total $139,500.  The plant faces $109,500 in penalties for 23 serious violations, which exposed plant employees to fire, explosion and safety and health hazards related to flammable chemicals. Inspectors found the plant stored thousands of pounds of flammable liquids on-site in indoor storage tanks. One tank overflowed in July 2014 because of a disabled or broken safety mechanism.  Here is a breakdown of the PSM related citations:

Last Updated on Monday, 15 December 2014 20:08
 
Safety Alert - PROHIBITED REFILLING OF DOT 39 SPECIFICATION CYLINDERS
Safety Info Posts - Safety Alerts
Written by Bryan Haywood   
Saturday, 13 December 2014 16:38

Screen Shot 2014-12-13 at 4.37.57 PMPHMSA has become aware of the sale of adapters designed to allow refilling of DOT 39 cylinders using larger cylinders (see attached photographs). These adaptors are sold at various retail outlets and online. Some of the common trade names are the “Mac Coupler”, “Mr. Heater” and “Shnozzle”. “MacCoupler” is manufactured by KM North America in Traverse City, MI.  “Mr. Heater” and “Shnozzle” are manufactured in China and sold on Amazon.  Additionally, several websites demonstrate how to use these adaptors.

PHMSA strongly recommends that the general public refrain from refilling DOT 39 cylinders because of the one-time use design of these cylinders, and the purchase and use of any adaptor sold as a means to refill DOT 39 cylinders creates a potential risk of fire, explosion, serious injury, and property damage.

CLICK HERE (pdf) for the full alert.

 
2014 Photo of the Week #51 (Electrical LOTO)
Safety Info Posts - Photo of the Week
Written by Bryan Haywood   
Saturday, 13 December 2014 13:01

Falls a bit short of 1910.333(b)(2) don’t you think?

"Lockout and Tagging." While any employee is exposed to contact with parts of fixed electric equipment or circuits which have been deenergized, the circuits energizing the parts shall be locked out or tagged or both in accordance with the requirements of this paragraph. The requirements shall be followed in the order in which they are presented (i.e., paragraph (b)(2)(i) first, then paragraph (b)(2)(ii), etc.).

nY9mc

Last Updated on Saturday, 13 December 2014 13:09
 
2014 Video of the Week #51 (5 FAQs on GFCI from NFPA)
Safety Info Posts - Video of the Week
Written by Bryan Haywood   
Saturday, 13 December 2014 00:00

With all the Christmas decorations up and all the cords running everywhere I thought this would be a good reminder.  As for work, remember since 2008 GFCI's are required when workers are using electrical cords and corded tools that are used during construction-like activities, including certain maintenance, remodeling, or repair activities, involving buildings, structures or equipment (1910.304(b)(3)(ii).

Last Updated on Saturday, 13 December 2014 13:01
 
Interesting PSM/RMP nuggets from the 12/11/14 Senate hearing on EO - IMPROVING CHEMICAL FACILITY SAFETY AND SECURITY
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Friday, 12 December 2014 20:47

Reading through the opening comments from OSHA and EPA at this weeks Senate Committee hearing discussing Executive Order 13650 - Improving Chemical Facility Safety and Security offered us some very interesting insights as to what OSHA and EPA are doing and planning in their efforts to improve process safety.  Here are some of those that I found most interesting.

Last Updated on Wednesday, 17 December 2014 10:03
 
The fundamentals behind “line breaking”
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Friday, 12 December 2014 19:47

My article earlier this year about line breaks on relief valve vent lines that are attached to a header/manifold got a lot of you to ask more questions about the practice of “line breaking” (or as some call it “process opening”).  I have tried to answer each question, but thought it may be helpful to explain the fundamentals of safe line breaking.  As we know, “line breaking” is the one safe work practice that OSHA and EPA mention in their process safety standards yet provide ZERO guidance on.  We can not even find a RAGAGEP or consensus standard for guidance; however, we do have some excellent historically practices we can rely on.

Last Updated on Friday, 12 December 2014 19:51
 
HAZWOPER Question... Does a person who will ONLY participate in Decon be required to have Operations or Tech level training?
Safety Info Posts - Emergency Response
Written by Bryan Haywood   
Friday, 12 December 2014 15:28

Scenario Facts:

  1. These workers would NEVER enter the warm or hot zone for defensive or offensive actionsrelated to controlling the uncontrolled release.  They will be in the warm zone as they will be participating in Decon, but this places them in the far edge of the Warm Zone (e.g. right at the Cold Zone line). 
  2. They are trained in HAZCOM of the chemicals involved in the uncontrolled release and the Decon chemicals. 
  3. They are trained in the PPE they will be using. 
  4. They are trained in the Decon Procedure which resides in the emergency response plan and all the equipment associated with the Decon procedure(s).

Will their regular safety training on these items make them "compliant" with 1910.120(q)?

 
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