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As usual, OSHA released their annual news at the National Safety Council's Congress and Expo... OSHA's Top 10 Standards Cited. The Top 10 for FY 2016* are:
*Preliminary figures as of Sept. 30, 2016
This article is intended to walk us through the DOT requirements for UNLOADING LPG and NH3 tanker trucks. In the DOT requirements covered in this article, we will see items that mirror OSHA's PSM and EPA's RMP requirements for DOCUMENTING Safety Systems and their intended functions. The material covered here should be incorporated into all UNLOADING SOPs and even in the risks evalauation for a facility to specify what they want in reagrds to the delivery truck(s) emergency discharge control equipment. Remember, one of the HIGHEST risk we face is when we are transferring thousands of gallons of our hazardous material(s) through temporary connections and a hose, so our level of SAFETY should rise to the level of risks. DOT has done a nice job structuring the requirements for Liquefied Compressed Gas (LCG) service and we should take heed as process safety and safety professionals.
This is an investigative report of the March 16, 2016 hydrogen/oxygen explosion at the University of Hawaii at Manoa campus (UH), in which a postdoctoral researcher lost her arm and sustained burns to her face and temporary loss of hearing. The postdoctoral researcher was working in a laboratory at the Hawaii Natural Energy Institute in the Pacific Ocean Science and Technology (POST) building. The University of California Center for Laboratory Safety, in its capacity as an independent third party review team, was contracted to investigate the circumstances that led to this laboratory accident. The report is separated into two sections. The immediate cause of the accident was traced to the digital pressure gauge which acted as a path to ground for a static charge that ignited the hydrogen/oxygen gas mixture contained within a 13 gallon (50 liter) pressure tank. Extensive analytical testing of an identical gas tank/pressure gauge system did not reproduce a stray electrical current within the digital pressure gauge suggesting that the initiation event was due to a static discharge generated in the tank or the researcher. The explosive gas mixture was most likely ignited when the statically charged researcher touched the metal housing of the gauge and a charge transfer occurred causing a corona or brush discharge within the gauge stem. While the likely point of initiation of the explosion was determined to be due to static discharge through the digital pressure gauge, it should be emphasized that there are numerous means by which a hydrogen/oxygen gas explosion can be initiated. It is imperative that, hydrogen/oxygen gas mixtures in the explosive range should not be stored, and experiments using hydrogen/oxygen gas mixtures, such as the culture of hydrogen-oxidizing bacteria, should undergo rigorous hazard analysis and mitigation efforts to eliminate possible sources of ignition.
The Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) urge employers (owners and operators) to conduct a root cause analysis following an incident or near miss at a facility.1 A root cause is a fundamental, underlying, system-related reason why an incident occurred that identifies one or more correctable system failures.2 By conducting a root cause analysis and addressing root causes, an employer may be able to substantially or completely prevent the same or a similar incident from recurring.
OSHA Process Safety Management and EPA Risk Management Program Requirements
The information in this report is preliminary and will be supplemented or corrected during the course of the investigation.
On August 27, 2016, about 8:26 a.m. eastern daylight time, tank car AXLX 1702, specification DOT 105J500W, experienced a sudden tank shell crack shortly after it was filled with liquefied compressed chlorine at a rail car loading facility in New Martinsville, West Virginia. During the 2 1/2 hours after the crack developed, the entire 90-ton load of chlorine released from the crack and formed a large vapor cloud that migrated south from the facility along the Ohio River valley. The weather at the time of the accident was lifting fog after sunrise, 72°F, and light wind from the north at 1 mph.
Fire and Building Code Officials are likely seeing the new Globally Harmonized System of Classification and Labelling of Chemicals (GHS) and new Safety Data Sheets with new chemical hazard pictograms. This ICC FACT SHEET is intended to provide Fire and Building Code Officials information relative to the modified OSHA Hazardous Communications Standard (HazCom) and address the potential impacts to current fire code and standard requirements related to hazardous chemicals and materials in the built environment.
Although the dates of these letters are eariler this year, they were just posted...
These past two weeks we have seen some interesting developments on two OSHA actions: 1) anti-retaliation provisions in the new record-keeping rule and 2) Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) in General Industry (Subpart D and Subpart I) . It seems a judge has delayed OSHA's enforcement of its anti-retaliation provisions in the new record-keeping rule from November 1st to December 1st. On a brighter front, we learned late last week that OSHA's Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) in General Industry (Subpart D and Subpart I) cleared the White House Office of Management and Budget (OMB). This effort started way back before my time (1990) and was recently attempted back in 2010; it now looks to get final passage.
In my HAZMAT classes, I always ask the question: A container of diesel fuel is at its flash point and a container of gasoline is at its flash point - an ignition source is present within the container - which container ignites first? Darn near 100% of the students will say the gasoline container and darn near 100% are WRONG! The reason: Diesel fuel has an LEL of around 0.5% and Gasoline has an LEL of around 1.5%, meaning that the LEL will be achieved in the diesel container MUCH FASTER. The ONLY thing diesel fuel has that makes it more safe is a HIGH flash point; however, when we expose diesel fuel to cutting torches and grinders we can spread the heat via conduction to the diesel fuel, raising the temp of the solution and thus we create a flammable atmosphere in short order! In fact, since most workers have some level of respect for gasoline and very little for diesel fuel we see more diesel fuel tank explosions than we do gasoline. Case in point...
In my upbringing in the chemical industry I had the opportunity to work with some outstanding engineers; too many to mention by name. These men and women took time out of their busy schedules to teach me process safety. One of these engineers was very strict about his process piping and every engineer in the units that were PSM (and then RMP later on) were expected to be intimately familiar with their process piping. So much, that the engineering manager would walk out to the unit, walk up to a run of pipe, touch it and the unit engineer would have to provide all the facts about that run of pipe. Could you answer these questions WITH DOCUMENTED PSI/MI data to support your answers?