This article was written By: Michael Farber, Senior Advisor to the Director of BSEE and I am posting it here as there is no means to "share" this great piece via social media.
General Motors (GM) recently released the findings of its internal investigation into the various failures that led to 12 fatalities and many injuries resulting from collisions caused by faulty ignitions switches in a number of its models. The company found that the ignition switches failed to keep the cars powered in certain circumstances, but they initially did not understand that this failure would prevent airbags from deploying. The internal investigation determined that there were at least 54 frontal-impact collisions in which airbags did not deploy as a result of the faulty ignition switches. GM used the faulty switches for 11 years without issuing any type of recall.
GM’s experience provides a window into how companies of any size and sophistication can lapse into systemic problems that can result in tragic consequences. Lessons learned from the GM experience can be applied to offshore oil and gas operations, as well as any other industry where lives are at stake every day. These lessons include:
Respondent has an RMProgram covered process, ammonia storage, which stores or otherwise uses anhydrous ammonia, an amount exceeding its applicable threshold of 10,000 pounds. Respondent has submitted and registered an RMPlan to the EPA. Based on an RMProgram compliance monitoring investigation initiated on January 31, 2013, the EPA alleges that the Respondent violated the codified rules governing the CAA Chemical Accident Prevention Provisions, because Respondent did not adequately implement provisions of 40 CFR Part 68 when it:
Respondent owns and operates a natural gas processing well site and facility, which includes a separator used for separating well fluids produced from the natural gas well into gaseous and liquid components and a tank battery which consists of interconnected storage tanks situated to receive output from the natural gas well and separator. Natural gas is a highly flammable gaseous hydrocarbon mixture containing methane, ethane, propane and butane, which are extremely hazardous substances listed in Table 3 of 40 CFR § 68.130 that may ignite, flashback or explode when exposed to a source of ignition. On Monday, February 3, 2014, multiple maintenance projects were underway at the facility. A coil tubing job was underway on one part of the facility. Cuttings and crude oil from the coil tubing job were placed in the "water storage tank" for storage. A welder and assistant were tasked with connecting a two inch water line running from the "water tank". Hydrocrarbon vapors collected in the two inch line due to the offloading of cuttings and crude oil that had been placed in the "water tank" from the coil tubing job. When the welder struck an arc on the two inch line, the flammable vapors ignited and traveled down the two inch line until they reached the water tank, which then exploded.
The Department of Homeland Security (DHS) continues to strengthen security at the Nation’s high-risk chemical facilities through the Chemical Facility Anti-Terrorism Standards (CFATS) program. Chemical Security Program Statistics as of January 5, 2015:
CLICK HERE for the DHS release
A question I am asked nearly each month is... do I have to have a person dedicated to operate the boiler and is this person restricted from performing any other functions while acting as the "boiler operator"? While I am not a "boiler expert", most of my clients have industrial size boilers associated with their chemical process(s) so I deal with boiler complaince, as it relates to PSM/RMP impacts on a regualr basis. All states have "Boiler Codes" and most are similar, but not exactly the same. Using Ohio's State Boiler Code, which was REVISED in 2014 and became effective on 1/1/2015, there are some methods in which an employer can implement sort of a PSM program for their boiler(s) and this would get them out of the boiler(s) having continuous, manned attendance during all times of operation for certain size and type boilers. But if the employer does NOT like the idea of Process Safety Management (PSM) being applied to their boiler(s), they will in FACT need to maintain continuous, manned attendance during all times of operation of certain size and type steam boiler(s). In fact, in many ways this newly revised section of the code is written so tightly that it is actually MORE demanding for operating a boiler without continuous, manned attendance than OSHA's PSM standard is for chemical processes! Here are the REQUIREMENTS in the state of Ohio, for those types and sized boilers, to operate without continuous, manned attendance...
The 1st Michigan worker death of 2015 occurred on January 15, 2015. Employers and employees are urged to use extreme care and safety diligence in all work activities.
Summary of incident: On January 8, 2015, a 37 year old sheet metal worker was in the process of torch cutting and welding when it is believed he had ignited the flame-retardant insulation between the hopper and building structure. The fire traveled up the 65-foot tall structure trapping the sheet metal worker inside the hopper. Fire-Fighters were able to extricate him, but he had sustained burns to his head and severe burns to his hand and wrist in addition to smoke inhalation. The sheet metal worker, one other employee, four sub-contractor employees, and two fire-fighters were transported to area hospitals. All but the sheet metal worker and one other employee were observed and released. The sheet metal worker succumbed to his injuries as a result of the fire on January 15, 2015.
Editorial Comment from me... the insulation was fire RESISTANT - not fire PROOF! I hear this ALL the time when I come across HW being done within feet of unprotected building insulation... "it fire proof insulation so we do not need to shield it".
If you need help or assistance in ensuring your workplace is safe, MIOSHA is here with resources to help. The Consultation Education & Training (CET) Division provides workplace safety and health training and consultations to employers and employees throughout Michigan free of charge. Contact CET today at 800-866-4674 or submit a request online at www.michigan.gov/cetrca.
Every life is precious. Our mutual goal must be that every employee goes home at the end of their shift every day!
Please use the comment section below to respond...
Tip: This is a general industry facility. The workers are contractors. The vessel is part of a PSM/RMP covered process. The vessel manway is only 16" in diameter.
Here is your scene:
Proposed Actions in OSHA's Inorganic Arsenic Standard Approval of Information Collection (Paperwork) Requirements
Inorganic Arsenic Standard requires employers to:
OSHA Proposed Action is the inclusion of 688 covered coal-fired electric power plants ...
Poor Design and Failure to Test Dust Collection System Among Causes of Flash Fire that Burned Seven Workers in 2012 (CSB)
The flash fire that burned seven workers, one seriously, in 2012 resulted from the accumulation of combustible dust inside a poorly designed dust collection system that had been put into operation only four days before the accident. The CSB investigation team concludes that the system was so flawed it only took a day to accumulate enough combustible dust and hydrocarbons in the duct work to overheat, ignite spontaneously, cause an explosion in the rooftop dust collector, and send back a fiery flash that enveloped seven workers. The CSB found that the ductwork conveyed combustible, condensable vapors above each of three tanks in the mixing room, combining with combustible particles of dust of carbon black and Gilsonite used in the production of black ink. The closed system air flow was insufficient to keep dust and sludge from accumulating inside the air ducts. But to make matters worse, the new dust collector design included three vacuuming hoses which were attached to the closed-system ductwork, used to pick up accumulated dust, dirt and other material from the facility’s floor and other level surfaces as a ‘housekeeping’ measure. The addition of these contaminants to the system ductwork doomed it to be plugged within days of startup. The report describes a dramatic series of events that took place within minutes on October 9, 2012...