Inspections vs Audits
The words "audits" and "inspections" often get used as if they are the same thing - THEY ARE NOT the same. I always like to say we inspect "things," and we audit those inspections. Much like my previous post earlier this month, explaining the difference between "examinations" and "inspections" as used in ASME B31 series; the terms have different meanings and we need to understand these differences. For example, we inspect our fire extinguishers monthly, but how often are we auditing those inspections? Inspections can become a "pencil whipping" exercise, as I am sure many of you have experienced. To avoid this from causing a failure in our layers of protection, we should "audit" those fire extinguisher inspections to verify that they are being done and to validate the data coming from those inspections. Another way of saying this is from the QMS mindset.... we inspect objects and audit processes. SMS Auditing: 1st Party, 2nd Party, 3rd Party
One of the more critical elements of an SMS is "auditing." In the Plan-Do-Check-Act model, auditing falls within the "CHECK" function. I like to say it's the element that keeps us honest and informed. And with that in mind, I break down my audits into three (3) layers: → 1st Party → 2nd Party → 3rd Party Each type of audit has its pros and cons, and the fact that the facility is auditing is critical; who is doing it plays a role, but not as critical. Here is how these audits work: Membership Content
Old secondary containment design vs. New secondary containment design
In the old days, the secondary containment around flammable liquid storage tanks could be a single system in which all the storage tanks sat. Today, that is NOT the case. Both NPFA 30 and IFC Chapter 57 require the secondary containment to be such that an LOPC from one tank can NOT impact the other tanks around it. They use the word "subdivided" to specify this. (emphasis by me) [My Safety] Thought of the Week... the SIF approach
If your team is focused on an event's probability or likelihood, you're NOT doing SIF! The Serious Injuries and Fatalities (SIF) model is intended to IDENTIFY events that have opportunities to cause life-altering injuries and death. And yes, most of these will (hopefully) have LOW frequencies/probabilities. So, to justify NOT responding to these LOW frequency - HIGH severity events by simply stating their likelihood is LOW is the opposite of the SIF model approach. If you are a facility that has a PSM/RMP management system, guess what? You're already utilizing the SIF model, as both PSM and RMP are safety management systems designed to manage LOW frequency — HIGH severity events. Using the same management system tools will drive the same improvements outside of the PSM/RMP Battery Limits. Safety Thought of the Week... Barrier/Controls/Safeguards Management
The purpose of barrier[/controls/safeguards] management is to make the kind of implicit controls explicit: to be clear about exactly
Source: Human Factors in Barrier Management, Prepared by a CIEHF Working Group comprising: Ron McLeod, Ian Randle, Rob Miles, Ian Hamilton, John Wilkinson, Christine Tomlinson, Gyuchan Thomas Jun, Tony Wynn. December 2016 Line Break gone bad (Cl2 cylinder change)
Eight people, including five (5) contract workers and three (3) fire service personnel, were admitted to the hospital after they inhaled chlorine gas following a leakage at a water treatment plant. EPA RMP citations @ chlorine, bleach, and hydrochloric acid facility (Cl2, H2, HCL & $264K w/ $363K SEP)
Respondent operated a facility (the “Facility”) to manufacture chlorine, bleach, and hydrochloric acid. Respondent produced, used, or stored more than 2,500 pounds of chlorine at the Facility and was subject to the requirements of CAA § 112(r)(7). Respondent produced, used, or stored hydrogen at the Facility and was subject to the requirements of CAA § 112(r)(1). Respondent was subject to Program 3 requirements because it had public receptors near the endpoint for the worst-case release and was subject to the OSHA process safety management standard set forth in 29 C.F.R. § 1910.119. Based upon the information gathered during the Investigation, EPA determined that Respondent violated certain provisions of the CAA. Differences between a H-2 and H-3 occupancy
In terms of Fire and Building Codes, we have five (5) recognized areas associated with handling hazardous materials. We refer to these high-hazard areas/occupancies as "Group H". High-hazard Group H occupancy includes, among others, the use of a building or structure, or a portion thereof, that involves the manufacturing, processing, generation or storage of materials that constitute a PHYSICAL or HEALTH HAZARD in quantities over those allowed in control areas complying with Section 5003.8.3, based on the maximum allowable quantity limits for control areas outlined in Tables 5003.1.1(1) and 5003.1.1(2). Hazardous occupancies are classified in Groups H-1, H-2, H-3, H-4 and H-5 and shall be in accordance with this code and the requirements of Section 415 of the International Building Code. Hazardous materials stored or used on top of roofs or canopies shall be classified as outdoor storage or use and shall comply with this code. H-1 buildings and structures contain materials that pose a detonation hazard, such as explosives. H-5 is specific to semiconductor fabrication facilities and comparable research and development areas. H-4 buildings and structures containing materials that are health hazards where materials such as Corrosives, Highly toxic materials, and Toxic materials are present. So that leaves us H-2 and H-3 areas, which, by me posting this under my Flammable Liquids category, you might have figured out that these two (2) hazardous occupancies are about flammable liquids and gases. But why have two (2) different ratings for the same hazard? "Normal venting" for aboveground tanks
During a recent design review, we encountered some questionable "normal breathing" designs. I have always used the simplest of tests to ensure the tank has ADEQUATE venting during filling and emptying. Although OSHA allows the designer to use API 2000 (1968) or "other accepted standards," the simplest test is that the VENTING capability MUST be as large as the filling or withdrawal connections, but in no case smaller than 1.25". However, unfortunately, designers fail to read ALL of .106(b)(2)(iv), which goes on to state: (emphasis by me) If any tank or pressure vessel has: Condensing water vapor creates a vacuum, destroys tank
"We were doing some cleaning at the end of yesterday. I boiled some water in the HLT to pump through the heat exchanger. At the end of the day, there were 40-50 gal left in our 3bbl HLT. I turned off the heat and went home for the night. The next morning, I came into the brewery to find an imploded HLT. I had clamped the lid on to keep humidity down in the building, and the cooling air/water in the HLT caused the tank to implode." Source: www.probrewer.com Implosion of ISO container during transfer (Vent valve NOT opened)
An ISO container, partly filled with Monoethylene Glycol (MEG), imploded on the back deck of a ship, spilling around two cubic meters (528 gallons) of MEG onto the deck and to sea and causing unrepairable damage to the tank itself. There were no injuries. The tank was a 26-cubic-meter tank containing ten cubic meters (6600 gallons) of MEG. The implosion happened due to a vacuum created inside the tank when the MEG was pumped out into a storage reservoir on the vessel during mobilization. |
Partner Organizations
I am proud to announce that The Chlorine Institute and SAFTENG have extended our"Partners in Safety" agreement for another year (2024) CI Members, send me an e-mail to request your FREE SAFTENG membership
Member Associations
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