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:
Summer’s here and temperatures are rising in the Southwest. Extreme heat kills dozens of workers every year, and sickens thousands more. Tips and tools from OSHA can help keep workers – and others – safe. Among the most at-risk industries are construction, transportation, agriculture and landscaping. New and temporary workers are especially susceptible to heat-illness and death due to lack of acclimatization.
Anyone who has done any audits knows this question carries a lot of weight, since cylinders "in use" have different safety requirements versus cylinders that are "in storage". The great safety folks at OR-OSHA have once again provided a really nice flow chart we can use to establish the state the cylinder is in so that the proper safety rules can be applied to it. And yes, these rules are ONLY enforceable in the state of Oregon, but wow what a nice tool we can use in any workplace - even though OR-OSHA is years ahead of Federal OSHA in their compressed gas safety standards! I would also like to mention that OR-OSHA has also re-defined how cylinders of flammables and oxidizers can be "separated" by means other than 20' separation. Noncombustible barriers modified or constructed after May 1, 2015, must meet the following additional minimum requirements:
On Jan. 20, a pressure-relief device released flammable gas and liquid into the atmosphere; it burned for more than two hours. OSHA investigated the facility and cited the employer for one willful and six serious safety violations. The violations included failing to train operators, update operating procedures, conduct a management of change analysis when changing software and hardware, conduct periodic inspections and document inspections on emergency shutdown devices.
Respondent owns and operates a Power Plant ("Facility") which produces processes, handles, or stores, among other things, hydrogen peroxide, which is an extremely hazardous substance when stored in a carbon steel tank and produces hydrogen, a regulated substance, when reacting with carbon steel. On July 25, 2014, there was an incident in which a tank had an uncontrolled release of pressure from the Hydrogen Peroxide tank. The 7000 pound carbon steel tank liberated from its foundation, separated from its bottom at the weld seam, and jettisoned 570 feet to the South West of the Facility. The 1200 gallons of hydrogen peroxide were released to the environment and leaving the water treatment system inoperable. This resulted in a plant forced outage of 48 hours and mitigation costs of approximately $100,000. There were NO injuries or fatalities. Respondent’s investigation revealed that…
OSHA issues proposed rulemaking clarifying the ongoing obligation to make and maintain accurate records of work-related injuries and illnesses
OSHA today issued a Notice of Proposed Rulemaking that clarifies an employer’s continuing obligation to make and maintain an accurate record of each recordable injury and illness throughout the five-year period during which the employer is required to keep the records. OSHA is issuing this proposed rule in light of the decision of the U.S. Court of Appeals for the D.C. Circuit in AKM LLC v. Secretary of Labor (Volks) to clarify its long-standing position that the duty to record an injury or illness continues for as long as the employer must keep records of the recordable injury or illness. The proposed amendments add NO NEW compliance obligations; the proposal would NOT require employers to make records of any injuries or illnesses for which records are not already required. The proposed rule will be published in the July 29, 2015, issue of the Federal Register. Members of the public can submit written comments on the proposed rule at http://www.regulations.gov, the Federal e-Rulemaking Portal. See the Federal Register notice* for submission details. Comments must be submitted by Sept. 27, 2015.
On July 22, OSHA issued eight serious safety citations from an inspection that was NOT initiated as a PSM inspection, but after determining that the company was using flammable liquids above the threshold quantities that could present a potential for a catastrophic event. Business was cited for not implementing five elements of the PSM standard, including process hazard analysis, operating procedures and training; and not preventing the sudden startup or movement of equipment during service and maintenance, a procedure known as lockout/tagout. Proposed Penalties are $50,400. Here is a breakdown of the citations:
This paper company had 39 VPP Sites in 2013 and today they were placed in OSHA's SVEP for this incident. Here is a breakdown of the citations that took them from VPP to SVEP. A 57-year-old general mechanic was removing burned filter bags of combustible fly ash dust from a dust collector in the facility’s power plant and replacing them with new bags when the fly ash ignited. He sustained severe burns as a result and subsequently died.
Today OSHA announced that they have placed International Paper (IP) into their Severe Violator Enforcement Program (SVEP) following a combustible dust ignition incident involving fly-ash at one of their facilities. This development is HUGE in the respect that IP was once one of OSHA's top participants in the Voluntary Protection Program. To go from one of OSHA's top performers to the SVEP is quite a shock to a safety pro who sort of grew up stealing IP safety programs for use at Westvaco. I can still remember the very first VPP Star site I ever visited was an IP plant and I was so impressed it left a lasting impression on me to this very day. I always morn the loss of life, especially when it was a workplace accident that could and should have been prevented, but to place a company in the SVEP implies they are a "severe violator" and how can a company be such a presence in the VPP and be in the SVEP. (FYI... in 2013 IP had 49 VPP sites). I get the SVEP and believe in it's need for OSHA to effect change in workplace safety; and I even could see the rationale behind DuPont... multiple fatalities at multiple facilities over a several year period. But how does a company with 49 VPP sites in 2013 make it to the SVEP in 2015? I understand IP had four (4) employee fatalities and one (1) contractor fatality in 2014 and this is UNACCEPTABLE, but when your using OSHA measurements and your rates are:
Employer(s) with employee(s) exposed to PSM-covered processes formerly exempted under OSHA's 1992 interpretation of "retail facility" now must comply with the requirements of 29 CFR 1910.119 if the facility, or portion of the facility processing the highly hazardous chemical, does not fall into the North American Industrial Classification System definition of retail trade (NAICS 44 and 45). OSHA understands that these facilities, although currently regulated by the EPA under the Risk Management Program (RMP) regulation 40 CFR 68, must undertake some new activities to become PSM-compliant. OSHA also understands that the actions involve initiating administrative programs and undertaking hazard identification and corrective actions that may require some lead time. With these factors in mind, OSHA offers this additional guidance when inspecting facilities formerly exempted from PSM because of the 1992 retail interpretation.
Today, OSHA issued their revised policy on their “retail exemption” and this change in OSHA enforcement will actually impact thousands of businesses who have submitted a Risk Management Plan. It all comes down to how EPA instituted their “Program Levels” when they implemented their RMP Rule. EPA has always said that if your process was already covered by OSHA’s PSM standard you automatically fall into Program 3. But if your process was not covered by PSM, then your program was eligible to be in Program 1 or 2; which require MUCH LESS than the full blown Program 3. Here is how EPA lays out their Program Levels…