On-Duty Firefighter Fatalities Involving Confined Spaces, 2003 – 2012 (NFPA Fire Analysis and Research Division)
Seven (7) incidents were found in a search for firefighter fatalities involving confined spaces. Eight firefighters were killed in these seven incidents. The victims were not necessarily in the confined spaces when fatally injured. Five of the seven incidents were investigated by the National Institute for Occupational Safety & Health (NIOSH). The investigation summaries and links to the complete investigation reports are shown here.
EPA RMP citations @ aerosol and non-aerosol product manufacturing and packaging facility (Flammable & $57,369 w/ $147K SEP)
Respondent is the operator of an aerosol and non-aerosol product manufacturing and packaging facility. The Facility, including its chemical storage tanks, is located less than 0.1 mile from the nearest neighboring commercial/industrial facility. There are several commercial facilities within a 1,000 foot radius of the Facility. Respondent manufacturers and packages into personal-sized containers a number of common cosmetic and home-use fragrance aerosol products using various aerosol propellants, including pure difluoroethane and blended combinations of difluoroethane-isobutane, difluoroethane-propane, and difluoroethane-isobutane-propane. On April 1, 2013, EPA conducted an inspection at the Facility to evaluate Respondent's compliance with the requirements of the CAA's risk management program. During the inspection, EPA observed four horizontal ASTs (two 2,550 gallon with maximum 16,878 lbs. capacity each and two 1,990 gallon with maximum 7,983 lbs. capacity each) situated in an outdoor Propellant Storage and Transfer Yard ("Tank Yard").
This decision covers several interesting items and sets a HUGE precedent for RESPONSIBILITY of PHA and Audit items from the PREVIOUS owners PHAs and Audits. The decision CONFIRMED that "utilities" within the process, in this case a "positive pressure unit" on a control room ventilation system, is a piece of COVERED EQUIPMENT. It also establishes minimums for when an employer uses "alternatives" to labeling each container of hazardous chemicals, being that the said containers were process vessels. The commission vacated two citations, which the machine guarding item involving an unguarded horizontal merely because OSHA could not show "exposure to the hazard" and an MOC citation since the use of steam lances was a "common occurrence at the refinery". The item regarding the PHA and Audit items from a previous employer/owner could be a HUGE precedent for future sales of facilities that have covered processes. Here is the case...
This is a very interesting AND disappointing decision by the commission. They accepted a PPE Hazard Assessment done at a distribution center in AR for a facility in TX. The business argued that the 100+ distribution centers around the country are identical with identical job functions. The commission, although they state otherwise, appears to be saying that since there was an "absence" of injuries in any substantial numbers there was not enough data to make the employer aware of the presence of hazards!!!! At least that is how I read this. This sets us back a bit, as we routinely identify hazards at facilities that require PPE and the facility will try and argue that no one has suffered an injury from said hazard "yet". I always thought the purpose of PPE "HAZARD" assessment was to identify "hazards" and not injuries. Granted using injury data can point us in the right direction, but IN NO WAY should a "hazard(s) assessment" be limited to an injury log analysis. Anyway, here is the OSHRC decision...
EPA RMP General Duty Clause citations @ Coke facility (Flammables; $50K - Failure to maintain desiccant dryer led to explosion)
This is not just another RMP General Duty Clause case. This case centers around a “critical utility” and how its FAILURE led to the release of a flammable gas and explosion. And the critical utility was the plant air system and the critical component was air dryer. The facility had recognized these systems as critical AND had the air dryer on an inspection schedule. Each shift, facility employees inspected the desiccant crystals in the air dryer system to ensure that the desiccant crystals are blue in color, which indicates that the air is dry. Employees then record the results on a checklist. The review of these records revealed that during the time period from January 22, 2014 until the time of the incident, area operators had noted the desiccant's LACK OF blue color on the inspection checklist, but no actions were taken to address this condition. The presence of moisture in the lines in extremely cold temperatures led to the failure of the west flare stack's valve to open due to a frozen air-line.
OSHA’s Process Safety Management Standard is NOT the only standard that requires “verification of knowledge” after training
In the PSM/RMP world, the battle rages on with regards to “verification of knowledge” for those receiving training related to their work in, on and adjacent to a PSM/RMP covered process. Yet for those safety professionals not working at a PSM/RMP facility, you too have a standard, that will just about cover ALL workplaces, that REQUIRES the employer to ensure workers understood the training. That standard is 1910.132(f)(2)...
Period: 30 days, 3/19/15 to 4/18/15
New Inspections: Opened in the last 30 days = 570
Closed Inspections: Closed in the last 30 days = 1,235
Ongoing Inspections: Opened prior to 30 day reporting period and still not closed = 110,342
Inspections with Violations = 129
Inspections with no Violations = 441 (Based on number of New Inspections only)
Assessed Penalties= $0.3M (Assessed Penalties for violations issued under New Inspections only)
On May 24,2012, EPA conducted a compliance inspection of Respondent's facility to determine compliance with the Risk Management Program ("RMP") regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Act. EPA found that the Respondent had violated regulations implementing Section 112(r) of the Act by failing to comply with the regulations. The Alleged Violations And Proposed Penalties are:
EPA RMP General Duty Clause citations @ diesel facility (Flammables; $30K - Piping Corrosion led to failure and VCE)
Respondent produces processes, handles, or stores, among other things, propane, hydrogen. isopentane, pentane, isobutane, and methane, which are all listed at 40 CFR Part 68 as extremely hazardous flammable chemicals. On August 3, 2014, there was a release of flammable substances from piping at the facility and a fire ensued. There were no injuries or fatalities; however, there was significant property damage to the facility's infrastructure. Respondent's investigation revealed that the fire resulted from a hole in process pipping at the facility allowing the release of flammable substances, which subsequently came in contact with an ignition source. The hole resulted from internal corrosion. Respondent failed to design and maintain a safe facility and did not take such necessary steps to prevent accidental releases by allowing internal corrosion on process piping that led to the release and subsequent fire. Respondent's failure constitutes a violation of the general duty clause in section 112(r)(1) of the CAA. Respondent is therefore subject to the assessment of penalties pursuant to sections 113(a)(3) and 113(d)(1)(B) of the CAA for violation of the general duty clause of section 112(r)(1) of the CAA. EPA and Respondent agree that an appropriate penalty to settle this matter is thirty thousand dollars ($30,000). CLICK HERE for the CAFO
You spend enough time working on Lockout/Tagout (LOTO) you are bound to come across some crazy situations. Luckily I have some world class clients who not only allow me to share my "interesting finds" but encourage me to share with all of you. This most recent find was at an OSHA VPP STAR site. We have been hired to do program specific audits each quarter, with an emphasis on energy control. This means even though I may be auditing flammable liquids this quarter, I am ALWAYS auditing LOTO and conducting "periodic inspections" (and yes I am an "authorized employee" within their LOTO program - I wrote it, wrote 99% of the machine specific control plans, and still do all the LOTO training at the facility). For the most part this facility KNOWS LOTO and LIVES IT DAILY; but we all have flaws - no one or no facility is perfect. Hence why we need LAYERS of PROTECTION in all our safety efforts. So today I was making my rounds talking with everyone and came across one of the safety committee members who was cleaning a piece of equipment. He knew I was there to do an audit, as he had participated in many audits with me before. He was PROUD and CONFIDENT of his ability to meet all LOTO requirements. But, the good will ended there. Here is the image of his electrical isolation - do you see anything wrong?
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.