Even in "complex energy isolations" we MUST include specific procedures to VERIFY ZERO ENERGY of EACH isolation point (OSHRC)
This was a significant decision by the OSHRC as it answered the debate... do isolation plans associated with complex energy isolations need to include the means to verify Zero Energy State (ZES) for each isolated source? There answer... YES, and it MUST be DOCUMENTED in the isolation plan/worksheet. The refinery's arguments that the means to verify ZES was not required to be part of the written plan seemed only to annoy the ALJ. It all started in response to a fire in the refinery’s crude oil unit; OSHA inspected the Refinery on October 24, 2013. The fire broke out after hydrocarbons leaked into the air while removing a pump (line break/process opening) when a valve could not be closed 100% and was not recognized by the authorized employees. OSHA issued a citation alleging two serious violations and a proposed penalty of $14,000.00. Respondent withdrew its Notice of Contest as to Item 1 of the Citation. Thus, the only item under consideration is Citation 1, Item 2, and its associated penalty of $7,000.00. Respondent timely contested the Citation. The trial took place on April 29–30, 2015. Five witnesses testified at the trial: |
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