Full disclosure, I do PSM/RMP audits, but that does not change the facts that I will present in this article. Over the past couple of years I have seen first hand companies cancel or fail to schedule their 3-year PSM/RMP audits because their State EPA, Federal EPA or OSHA did a PSM/RMP inspection at their facility and they feel this “inspection” counts as a 3-year audit. They could not be further from reality and here’s why:
A food cannery faces $143,550 in federal penalties after a worker, 35, fell more than 17 feet into an empty sauerkraut vat and broke multiple bones. The inspection that followed was the fourth time since 2011 that OSHA has cited the company for failing to protect workers from fall and machine hazards. On April 13, OSHA issued one willful, two repeat, five serious and one-other-than serious safety violations after the Oct. 27, 2015 injury inspection. The agency found similar violations at the facility in 2013 and 2015. Here is a breakdown of the PRCS citations (as well as the others):
These citations are the FIRST OSHA citations using 1926.1201-1213, OSHA’s confined space in constructionOSHA’s confined space in construction standard. It is IMPORTANT to point out these citations involved work at a waste-water treatment plant (WWTP) which is normally a workplace that would fall under OSHA's GENERAL INDUSTRY standards; however, the work being done INSIDE the 54" pipe was CONSTRUCTION WORK. This case also involved sub-contractors who were also cited for PRCS issues. This inspection came about because a worker, 42, was leak testing joints inside a 54-inch round pipe and suffered fatal blunt force injuries in October 2015, when an inflatable “bladder” ruptured. Here is a breakdown of the 1926.1201-1213, OSHA’s confined space in construction standard citations:
PLEASE pay particular attention to the citations regarding RESCUE from this 54" pipe!
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 arguments the refinery put forth 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 refinery’s crude oil unit, OSHA conducted an inspection of the Refinery on October 24, 2013. The fire broke out after hydrocarbons leaked into the air during the removal of a pump (line break/process opening) when a valve was not able to 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 trial:
What does 527 CMR 33.00: Hazardous Material Process or Processing have to do with the Boston NH3 Fatality?
On March 23rd a worker at a seafood processing building/warehouse in Boston, MA was killed in a catastrophic release of anhydrous ammonia. Since then there has been much speculation as to how this tragedy occurred and whether or not the facility's refrigeration process fell under OSHA’s PSM and EPA’s RMP standards. As it appears at the time of this writing, neither OSHA’s or EPA’s process safety standard(s) applied to this refrigeration process as the process appeared to be under the 10,000 pounds threshold(s). But the state of Massachusetts has it’s own version of Process Safety standards in the way of 527 CMR 33.00: HAZARDOUS MATERIAL PROCESS OR PROCESSING and this state code does indeed cover this refrigeration process and this fatal accident. The “purpose” of 527 CMR 33.00 was to set state requirements lower than OSHA PSM thresholds and to create local fire department permit requirements for facilities engaging in the processing of certain hazardous materials. The code is based on a classification system and requires disclosure and evaluation regarding a facility’s hazardous material operations. Here's more on the state's (Massachusetts) Hazardous Material Processing Code and how it would apply to this ammonia refrigeration process:
One of the means to protect an OUTSIDE atmospheric storage tank is a weak roof-to-shell seam. As we can see in this video, a diesel tank at wharf in Apia, Samoa was equipped with such a means of fire venting. I am assuming this on the basis of the information we can obtain from the drone footage. We see the other two (2) diesel tanks do NOT have a normal emergency vent and the fact the the entire roof is gone on the tank that is on fire. This means of emergency venting is permitted ONLY on OUTDOOR tanks and we can see why, but they do work. Had the responding FD had an adequate supply of foam, this fire could have easily (relatively speaking) extinguished. Notice how the tank integrity was maintained and the diesel was contained within the tank.
NOTE: this tank fire was caused by Hot Work on the tank while the tank was in service. Diesel fuel will EXPLODE and in fact it's LEL is HALF of Gasoline's LEL!!! Of course it's FP is 145F, but once we get vapor present, it takes only 0.5% to be explosive!
CLICK HERE to see the location of the tank roof and additional footage.
This video from India is an excellent lesson in how NOT to handle compromised containers. In the USA we have an established practice of removing as much of the HAZMAT as we can before we attempt to move the container. As you will see in this video, things can go badly really quick when attempting to move a container that has been compromised and still contains the HAZMAT. The HAZMAT involved in this video is anhydrous ammonia...
Sometimes I come across some items as I do work for clients that are priceless in helping us make our case for safety and this one is a "feather in our [hard] hat". Apparently some employers in the state of California decided that using pressure vessels built to some code other than ASME Section VIII was a means to "save money" or for some other crazy reason. The state of CA took issue with this practice and issued a memo way back in 2006 explaining how these businesses could get an official exemption from CAL-OSHA to use a "non-coded" pressure vessel. Their request for information to determine if such a vessel could be used safely speaks volumes to "pressure vessel safety" and provides us some excellent insight into what goes into a pressure vessel safety management program...
We have all seen the videos and pics of the storage racks collapsing and most of us are amazed at how violent these incidents are; yet how many of us can walk through our storage areas and not find missing anchor bolts, corroded and damaged structural components, no posted load ratings, or out-of-straight support columns? In a recent OSHA citations during a PSM inspection, OSHA issued a citation using their General Duty Clause (GDC), officially called a "5(a)(1)" for the condition of some storage racks within the facility (see citation below). In this GDC citation OSHA referenced ANSI MH 16.1, Specification for the Design, Testing and Utilization of Industrial Steel Storage RacksSpecification for the Design, Testing and Utilization of Industrial Steel Storage Racks (Link is to a FREE Copy of 2008 Revision, w/ 2012 being the latest revision).
OSHA has cited a food manufacturing company for 25 serious and one other violation for exposing workers to hazardous chemicals, electrical dangers and fall hazards. OSHA discovered the violations after an inspection of the facility. The agency inspected the plant after an evacuation of the facility sent workers to the hospital as a precaution on Oct. 16, 2015. The citations include multiple violations of OSHA's process safety management regulations; exposing workers to hazardous chemicals, respiratory protection, electrical hazards, and the failure to provide fall protection to employees. Proposed penalties for the employer total $124,000. Here's a breakdown of the PSM and PSM Related citations: