Period: 30 days, 7/17/15 to 8/16/15
New Inspections: Opened in the last 30 days = 4,371
Closed Inspections: Closed in the last 30 days = 4,319
Ongoing Inspections: Opened prior to 30 day reporting period and still not closed = 119,926
Inspections with Violations = 113
Inspections with no Violations = 4,258
Assessed Penalties= $0.4M
As I have written earlier, the new refrigerant HFO-1234yf is a Category 1 Flammable Gas. This flammable gas is stored under pressure as a liquid, which by definition makes this material a candidate for a BLEVE risk assessment. For those that are not familiar with the acronym BLEVE, it stands for Boiling Liquid Expanding Vapor Explosion and this week's "Video of the Week" is a Transport Canada training video on BLEVEs. This type of vessel failure takes the term "catastrophic failure" to new heights and in a some-what famous BLEVE incident a LPG railcar traveled over 3,500 feet after it BLEVE'ed. BLEVEs are indeed an event that is considered to be a "Low Frequency - High Severity" and thus often times are over looked as a plausible scenario. I have been sorely disappointed in some of the responses clients and I have received from so called "reliable sources" (not so much any more in my eyes). One such response was "this refrigerant is a mildly flammable material and carries no risks for a bleve". Really? You can call this Category 1 Flammable Gas a "mildly flammable" all day long, as that has ZERO, zilch, NADA, zip to do with estimating BLEVE risks!!! In fact, the most recent BLEVE that resulted in three fatalities was a Carbon Dioxide (CO2) Tank in Germany and if you were not aware - CO2 is NOT a flammable gas - and in fact it is used as an EXTINGUISHING agent around the world. So if HFO-1234yf is a BLEVE risk, what does this mean to those facilities who store HFO-1234 in ASME pressure vessels? I will cover that answer in Part 5.
Dutch BLEVE Study (Department of Multi-Scale Physics, Faculty of Applied Sciences Delft University of Technology
While doing some a BLEVE risk assessment I came across this 2007 research paper that I thought was an incredible read. If you are one who works with BLEVE risk this is a MUST READ; if your someone who finds BLEVEs interesting and want to learn the inner workings of a BLEVE, this paper breaks it down and challenges each failure mode (hot vs. cold BLEVE). During a BLEVE there is a LOT happening inside the vessel and EACH factor plays into the timing and severity of the BLEVE; this paper makes sense of these factors and really does a nice job breaking it all down.
CLICK HERE (pdf) for the paper in English
Cal/OSHA today issued 19 citations to a refinery for workplace safety and health violations following an investigation into the February explosion at the company’s Torrance refinery that injured four workers. The proposed penalties total $566,600. Eighteen of the citations were classified as serious due to a realistic possibility of worker death or serious injury. Six of these serious violations were also classified as willful because Cal/OSHA found that the refinery did not take action to eliminate known hazardous conditions at the refinery and intentionally failed to comply with state safety standards. The blast on February 18 was the result of a hydrocarbon release from the refinery’s fluid catalytic cracker (FCC) unit into its electrostatic precipitator (ESP). The hydrocarbons ignited inside the ESP, causing the unit to explode. Eight workers were decontaminated after the incident, and four were sent to hospitals for treatment of minor injuries. Cal/OSHA’s investigation concluded the following:
Cal/OSHA issued an order prohibiting use of the FCC unit on February 18, and that order remains in effect until the refinery can demonstrate that the unit is safe to operate. Here is a breakdown of the citations:
I have been seeing a lot of RMP citations for failure to UPDATE the facility's RMP every five (5) years. By far the number one issue this year based on the ESAs I have been trending. But one question comes to mind... RMP differs in PSM in a couple of ways, one way being that RMP requires the facility to have a documented "management system to oversee the implementation of the risk management program elements". If your forgetting to do your five-year update doesn't this indicate your management system is NOT functioning?!?!? For the life of me, I can not understand why EPA merely cites for not doing something every five years when the bigger issue is a FAILED MANAGEMENT SYSTEM which I can almost guarantee that if this simple requirement was missed there is much more missing within the RMP program at the facility! So when some people cry foul that EPA/OSHA issue too many citations, consider this trend. It would be EASY and logical for EPA to issue two citations for this failure to update and in my opinion, the FAILURE of the management system that should have directed someone to do the 5-year update is much more serious than merely missing a date. Here is EPA's RMP Management system requirements:
In the past couple of months OSHA has been rescinding LOIs and issuing new LOIs on PSM Retail Exemption and the 1% rule and at the top of these LOIs (posted on line) is a "blanket statement" from OSHA that I find sort of humorous and sad at the same time...
"OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov"
Did you catch it? Look below I have highlighted the ironic part of their blanket statement...
In Part 1 of this series I established how this material is a Category 1 Flammable Gas based on both the manufacturer's SDS and OSHA's Hazardous Communications Standard Appendix C. In this article I wish to address how a HFO-1234yf storage tank, which is an ASME pressure vessel, should be labeled, versus how some have been found labeled. This article will apply to BOTH NFPA 704 "Diamonds" and the Hazardous Materials Identification System (HMIS). I have observed incorrectly labeled HFO-1234yf pressure vessels more times than I have seen correctly labeled vessels. I am trying to figure out this error came about, but my gut tells me we have once again placed too much emphasis on "marketing materials" rather than SDS data and in two cases, the manufacturer actually instructed the facility incorrectly to use the HMIS Flammable "2". Without question, HFO-1234yf is a Flammable "4" in both the NFPA 704 and the HMIS labels and here's why...
All year I have received dozens of phone calls and e-mails from friends and colleagues in the automotive industry regarding this new refrigerant for A/C units inside 2016 model vehicles. Over the next couple of months I will be posting a series of articles about this new refrigerant and the impact it is having on the automotive industry. This first article is to clearly establish this material is a CATEGORY 1 FLAMMABLE GAS and any facility that has over 10,000 pounds in their "process" has a PSM Covered Process. There has been much confusion over this new refrigerant and its classification. The makers of this refrigerant have been marketing their product as "mildly flammable" and this has caught a lot of safety departments off guard when the material actually arrives on site. But here are the facts...
OSHA has releases their REVISED Training Requirements in OSHA Standards (OSHA 2254-07R 2015)OSHA 2254-07R 2015). This publication provides a general overview of a variety of standards-related topics. This publication does NOT alter or determine compliance responsibilities which are set forth in OSHA standards, and the Occupational Safety and Health Act. Moreover, because interpretations and enforcement policy may change over time, for additional guidance on OSHA compliance requirements, the reader should consult current administrative interpretations and decisions by the Occupational Safety and Health Review Commission.
The respondent produces, processes, stores, and/or handles extremely hazardous substances, including hydrochloric acid (36%), due to its toxic and corrosive characteristics and propensity to volatilize in ambient air. On July 25, 2014, there was a release of hydrochloric acid (36%) at the Facility. An operator while on his normal rounds gauging the Boiler I house Sump, noticed an abnormal vapor cloud coining fro1n behind Warehouse #2. The operator immediately notified a Shift Leader, who identified the vapor cloud as hydrochloric acid (36%), and immediately shut down the pumping of hydrochloric acid (36%) from Line 3 through the pipe rack behind the warehouse. Facility later determined that the release was caused by a breach of a flange connection on a 2" pipe. The pipe consists of two components: a carbon steel outer structure that bears pressure and a teflon liner that protects the carbon steel outer pipe fro1n the hydrochloric acid traveling through the pipe. The carbon steel pipe had been severely corroded by hydrochloric acid that had permeated the teflon inner liner. Once the outer carbon steel pipe lost its structural integrity the teflon inner shell was unable to contain the pressure and failed at the flange connection. 3,280 pounds of hydrochloric acid (36%) were released during the incident.
Everyone once in a while we come across purged and pressurized enclosures during our PSM/RMP audits involving processes that contain/process flammable liquids or gases. These purged and pressurized enclosures are used in lieu of using enclosures that are either intrinsically safe or explosion proof. But this method of protecting the process from ignition sources is NOT as simple as some would hope; in fact the method comes with its very own Recognized and Generally Accepted Good Engineering Practice (RAGAGEP), NFPA 496: Standard for Purged and Pressurized Enclosures for Electrical Equipment. Here are some requirements that may be a surprise to some: