Anyone who has worked with ASME/API pressure vessel codes knows the basic language used to describe Relief Valve (RV) discharge locations... "discharge to a safe location".  This requirement applies to ALL relief devices on all types of equipment and although OSHA does not have a specific standard on relief devices and their design, they will use their General Duty Clause to cite employers who do not discharge their RVs to a safe location.  Case in point, in the tragic accident in GA last year involving Nitrogen where the facility had a Hydrostatic RV discharge inside the building...

OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to an employee in that the employee was exposed to asphyxia and hypothermia hazards created by a liquid nitrogen cryogenic system in which relief devices were not installed to discharge to a safe location:

a) New cryogenic freezer room - On or about January 23, 2017 an employee was exposed to asphyxia and hypothermia hazards while installing and/or testing a liquid nitrogen cryogenic system with over-pressure relief devices that could discharge into an unsafe area, such as the new freezer room work area.

In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification. This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

 

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to an employee in that the employee was exposed to asphyxia and hypothermia hazards created by a liquid nitrogen cryogenic system in which the outdoor bulk nitrogen tank was not labeled to correctly indicate the bulk tank internal pressure and house line pressure required for safe operation.

a) New cryogenic freezer room - On or about January 23, 2017 an employee installing/testing cryogenic freezers was exposed to asphyxia and hypothermia hazards when the outdoor bulk nitrogen tank was over-pressured due to a mislabeling of the tank internal pressure and house line pressure, causing the bulk tank contents to vent inside the new room.

In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification. This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records

 

CLICK HERE for the OSHA file

 
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