One of the top questions we get when working with clients whose primary business is storing, handling, and processing flammable liquids is...
How many flammable storage cabinets can we have in the same area?
This answer used to be easy, but these days - not so much. Back in the day, NFPA 30 (2000 Edition) stated the answer clearly...
In 2011 someone wrote to OSHA and specifically asked for clarification on the use of the words "or" and "nor" in the paragraph Design, Construction, and Capacity of Storage Cabinets-Maximum Capacity, 1910.106(d)(3)(i), which states:
"Not more than 60 gallons of Class I or Class II liquids, nor more than 120 gallons of Class III liquids may be stored in a storage cabinet."
This language is an adaptation of similar language in section 4210 of the 1969 edition of the National Fire Protection Association's (NFPA) Standard 30, Flammable and Combustible Liquids (source standard for 29 CFR 1910.106), which states:
"Not more than 60 gallons of flammable or 120 gallons of combustible liquids may be stored in a storage cabinet."
The requestor correctly pointed out that the use of "or" and "nor" above is ambiguous and that users might interpret these requirements differently. They listed multiple possible interpretations in their letter, including, but not limited to:
With the explosion video in the SAFTENG FaceBook group this week, I thought I would share another "smoking" related item. These are far too common!
Anyone who has taken one of my HAZMAT or Process Safety training courses has heard about and seen video of the Atlas Foundry LPG BLEVE that occurred back in 2007. But in a recent process safety course, several students (volunteer FF's outside of their full time job at this PSM facility) debated on the facts of the incident, of which neither was even close to being factual. So as we approach the 10-year anniversary of this fatal accident and BLEVE I thought it would be a good idea to set the record straight with what actually happened and how it happened. And yes, this was another HAZMAT UNLOADING incident gone bad...
The U.S. Chemical Safety Board has released preliminary findings from its ongoing investigation of the toxic chemical release that occurred at a distilled spirits plant in Kansas on October 21, 2016. The CSB’s investigation into the release has identified several shortcomings in the design and labeling of loading stations, as well as adherence to chemical unloading procedures. The chemical release occurred when sulfuric acid was inadvertently unloaded from a tanker truck into a fixed sodium hypochlorite tank at the plant. The two materials combined to produce chlorine gas that sent over 140 individuals, both workers and members of the public, to area hospitals and resulted in shelter-in-place and evacuation orders for thousands of local residents. The CSB’s investigation found that at about 7:35 am, a tanker truck arrived at the facility to deliver sulfuric acid. There, a facility operator escorted the driver to a locked loading area. The operator unlocked the gate to the fill lines and also unlocked the sulfuric acid fill line. The CSB found that the facility operator likely did not notice that the sodium hypochlorite fill line was also already unlocked before returning to his workstation. The driver connected the sulfuric acid discharge hose from the truck into the sodium hypochlorite fill line. The line used to transfer sulfuric acid looked similar to the sodium hypochlorite line, and the two lines were located in close proximity. As a result of the incorrect connection, thousands of gallons of sulfuric acid from the tanker truck entered the facility’s sodium hypochlorite tank. The resulting mixture created a dense green cloud, which traveled northeast of the facility until the wind shifted the cloud northwest towards a more densely populated area of town. The CSB investigation concluded that emergency shutdown mechanisms were not in place or were not actuated from either a remote location at the facility or in the truck. The CSB found a number of design deficiencies that increased the likelihood of an incorrect connection, such as the close proximity of the fill lines, and unclear and poorly placed chemical labels. In addition, the CSB found that both the facility and trucking company did not follow internal procedures for unloading operations CLICK HERE for the CSB Press Release
U.S. fire departments responded to an average of 4,440 structure fires involving hot work per year. These fires caused an average of 12 civilian deaths, 208 civilian injuries and $287 million in direct property damage per year. From 2001-2015, five firefighters were fatally injured in four unintentional fires started by torches. Forty-two percent of the fires involving hot work in 2010-2014 occurred in or on homes, including one or two-family homes and apartments or other multi-family homes, while 58% occurred in or on-non-home properties.
No fewer than 60 fatal and non-fatal cases were documented in 2016. Of these, 30 (50%) were fatal and 29 (48%) of those cases were directly related to grain entrapments. In addition to the cases documented in 2016, cases that occurred in previous years continue to be added to the database due to ongoing discovery efforts. The total number of cases documented between 1962 and 2016 and entered in the PACSID is 1,935. Of those, 1,187 cases (61%) were reported as fatal and 1,432 (74%) involved grain storage and handling facilities. As noted in past summaries, the data presented do not account for all incidents involving agricultural confined spaces. There is no accumulative public record of these incidents due to the fact that there is no comprehensive or mandatory incident/injury reporting systems for most of agriculture; in addition, there has been reluctance on the part of some victims and employers to report non-fatal incidents, especially at farms, feedlots and seed processing operations. It is estimated that approximately 30% of cases go unreported. CLICK HERE for the 2016 Report
As we know "human factors" are specifically called in the OSHA's PSM standard and EPA's Risk Management Plan and even more specifically they are part of our Process Hazards Analysis (PHA). However, many do not understand what "human factors" are all about, so I thought I would share another picture I captured in my travels to help demonstrate a serious error in "human factors". Do you see the "conflict" in this picture? What am I suppose to do? Do we have conflicts like this in our covered process areas or in our administrative controls like our Safe Work Practices, Operating Procedures, and/or maintenance procedures? What would you in this situation?
The multiple-fatality explosion on October 17, 2016 explosion and subsequent fires at the german facility has been determined to be caused by a contractor cutting into an incorrect line/pipe containing flammable raffinate. Two employees of the on-site fire department and an employee of a tanker which was anchored in the harbor died in the accident. Another employee of the on-site fire department who was severely injured in the explosion died on October 29. Seven people were seriously injured and another 22 suffered slight injuries.
Course of events:
One of the most often overlooked requirements for piping installations is the proper leak/pressure testing of the piping BEFORE it is placed into service. The next major issue found, when piping is tested, is the manner in which it was tested. The 2014 and 2016 editions of ASME B31.3 makes it clear that hydrostatic testing is the PREFERRED means, then comes PNEUMATIC testing, and ONLY under certain conditions can we use alternative inspection techniques. In the 2016 edition they provide us with some clear criteria under which we can find Hydrostatic testing and pneumatic testing "impractical". Here's what the code says:
This week EPA's Administrator signed a proposed rule to further delay the effective date of the RMP rule amendments for 20 months until February 19, 2019. This action will allow EPA to consider several petitions for reconsideration of the RMP rule amendments and take further regulatory action. EPA will hold a public hearing regarding the proposed effective date. Written comments must be received by May 19, 2017.
A public hearing will be held in Washington, DC on April 19, 2017, at William J. Clinton East Building, Room 1153 (Map Room), 1201 Constitution Ave., NW, Washington, DC 20460, from 9:00AM - 4:00PM. The hearing will provide interested parties the opportunity to present data, views or arguments concerning the proposed effective date of the RMP amendments.
CLICK HERE for EPA info