Fire Protection Deficiencies to incorporate into our inspection programs and internal audit programs
Anyone ever completed any type of safety audit and not ended up with at least one item related to your fire protection systems? Anyone? I know I never have and I am a fanatic about my fire protection systems. I was trained to treat them as “gold”. No one touches them - PERIOD! Yet in all my years I can not recall having completed a safety audit where someone found something wrong related to my fire protection systems. So here are a few items that we can use to raise awareness about code compliance for our fire protection systems.
OSHA has issued several PSM citations at a natural gas processing facility from an inspection that began in October 2014. This was an unannounced planned Chem NEP inspection. Of special note, these violations include issues with not having a Car Seal Program for valves within the relief path(s) of several relief devices. OSHA referenced ASME Section VIII, but did not specifically reference Appendix M-5 which contains the requirements for when a block valve is placed in the path of the relief system. PLEASE see my 2011 article, Car Seal Program and Relief Valves regarding how to comply with ASME Section VIII Appendix M- 5.
Most everyone has seen a bollard; they may have not realized what they were seeing at the time, but most have seen one. But this group of people who have seen one grows much smaller when we begin to ask “what makes a bollard a safety device?” A couple of years ago I shared an engineering standard for bollards and vehicle protection. That page has been viewed more than 200,000 times since 2012, so there must be some level of interest in these safety devices. I lost count of the number of e-mails I received asking if the post was a “joke”, as who in their right mind would have an engineering design for a post?!?! Well a well designed, constructed, chemical process that utilizes mobile equipment within their process battery limits… that's who! Just last year we issued several audit findings for either the lack of or improper design of bollards protecting bulk tanks and other "critical" process equipment. These were PSM audits… so what RAGAGEP did we reference?
This is not the first time I have "beat up" on excess flow valves and the reliance on them as a "safeguard" in a PHA or process design. Both EPA and OSHA are on record stating their displeasure of claiming these valves as a safe guard. Now don't get me wrong, these devices WORK and WORK WELL when they are DESIGNED, INSTALLED, TESTED, and MAINTAINED per the manufacturer's requirements... and here lies the problem. These valves MUST be included in the PSI - Safety Systems with the engineering (i.e. sizing) documentation, as well as reside in the MI program for inspection and testing. Here is some language from one of the top manufacturer of these safety valves and we can see that these valves require a LOT of attention, which many facilities are lacking...
Each year more and more states are adopting International Codes. The chart below is a list of all states and US Territories that have adopted these codes, the code edition they adopted, whether the code is enforced state wide or local governments, etc. This listing is up-to-date thru February 2015. Are you complying with your state's HAZMAT, Fire, Building, and Mechanical Codes? Those of you working at facilities that handle/store hazardous materials, you should take some time out of your busy days and read those state codes that are applicable to your facility. I am not a big fan of using codes and standards to drive safety, but they do represent our lowest safety denominator for how we manage these hazards. OSHA and EPA regs get all the attention and $, but some of these codes contain some REALLY GOOD requirements that will add value to any safety program.
DIR Releases Status Report on Process Safety Management Regulatory Oversight of California's Petroleum Refineries
Christine Baker, Director of the Department of Industrial Relations (DIR), has submitted a legislatively-mandated status report on DIR and Cal/OSHA's Process Safety Management (PSM) Regulatory Oversight. The report is required pursuant to the Budget Act of 2014 (Provisions 1 and 2 of item 7350-001-3121, Chapter 25, Statutes of 2014). A new assessment on the state's oil refineries, implemented by DIR in 2013, requires refineries to provide funding support to DIR for Cal/OSHA's PSM refinery program. The funds, which are independent of the state's General Fund, have allowed DIR to expand the PSM staff from 10 positions in 2012 to 26 positions and supported eleven weeks of advanced technical training for the refinery inspectors. Cal/OSHA's PSM Unit is responsible for inspecting refineries and chemical plants that handle large quantities of toxic and flammable materials. Health and safety standards enforced by the PSM Unit, including adequate employee training, are intended to prevent catastrophic explosions, fires, and releases of dangerous chemicals.
On May 15, 2013, EPA conducted a compliance inspection of Respondent's facility to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.F.R. part 68 under section 112(r)(7) of the Act. The EPA found that the Respondent had violated regulations implementing section 112(r)(7) of the Act by failing to comply with the specific requirements outlined in the attached RMP Program Level 3 Process Checklist-Alleged Violations & Penalty Assessment (Checklist and Penalty Assessment). The Checklist and Penalty Assessment is incorporated into this ESA.
I am working on getting all of these RMP NOVs posted but found this one especially interesting...
XXXXXXXXXX did not address the impact of the lock-out of the factory workers in August 2011 and hiring all new replacement workers. Such extensive staffing changes could impact the safety and health of the XXXXX workers and should be included in the MOC review process. Center for Chemical Process Safety (CCPS) Guidelines for Management of Change for Process Safety section 3.4.2 Types of Changes to Be Managed include organizational and staffing changes.
So you have been "warned", now both OSHA and EPA are on record for issuing citations against staffing changes without the aid of an MOC.
CLICK HERE to see all the citations
Unsafe use of chlorine gas was discovered by OSHA in September 2014 after a complaint prompted an inspection. Investigators found employees endangered by permit-required confined space hazards while working in foundry furnaces. As a result, OSHA issued 31 serious health and safety citations with proposed penalties of $160,200. Inspectors determined the company failed to train workers on hazardous chemicals used at the foundry; store oxygen and fuel-gas cylinders properly, and protect workers from dangerous machine parts. The agency also found forklifts with defects in use. Company also failed to conduct audiometric testing; ensure hearing protection was worn; and to train employees on noise hazards. Here is a breakdown of the PSM related citations:
We have become aware that insufficient lubrication may have been applied to the bypass valve assemblies on FireHawk M7XT Air Masks when manufactured. A lack of sufficient lubricant could cause the bypass assembly to become difficult to operate or possibly inoperable. No injuries have been reported. Until your affected units have been serviced as described in this notice, please be aware of any degradation in how easily the bypass valve operates when performing your pre-use functional tests as described in the users’ instructions. If degradation is apparent, that Air Mask should be removed from service until it is corrected. CLICK HERE for the Safety Notice
Today marks the 1-year Anniversary of "The Back Bay Blaze" where UNSAFE Hot Work Practices claimed the lives of two Boston FF's
Today marks the one-year anniversary of the 2014 Boston Brownstone fire that claimed the lives of two Boston firefighters, Lt. Edward Walsh and Michael Kennedy. The fire was found to have started from welding that took place on a metal handrail in a unit next door. The 2014 fire was a nine-alarm fire that took place on March 26, 2014 at 2:42 p.m. in a four-story brick row house at 298 Beacon Street in the Back Bay of Boston. The fire also injured eighteen others, including thirteen firefighters. The fire was believed to have been started by welders working at a nearby iron railing. On June 9, 2014, a report was released concluding that Walsh and Kennedy's deaths were both accidental. On April 4, a number of fire officials, including Boston Fire Commissioner John Hasson, blamed the fire on sparks originating from welding being done on a nearby iron railing. The welders, according to these officials, were operating without a permit and apparently tried to warn others after the fire started. However, the welders did not call 911, which prompted Ken Donnelly and other Massachusetts politicians to call for criminal charges to be brought against the welding company.