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In this week’s Newsletter
Side Bar Items:
More indications of OSHA’s push for Flame Retardant Clothing (FRC)
OR-OSHA’s recently released their PPE Directive, which differs from the Federal OSHA PPE Directive in how Flame Retardant Clothing issues are addressed. The Federal Directive covers who has to pay for the FRC, but OR-OSHA goes a bit further by having their CSHO’s reference NFPA 2112, Standard on Flame- Resistant Garments for Protection of Industrial Personnel Against Flash Fire, and NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire. Here is what their Directive states.
SPECIFIC PPE INSPECTION
PROCEDURES: Determine whether the following items are in compliance with the standard:
A. Flame-resistant (FR) clothing. Employers are required to provide, at no cost to employees, FR clothing for applications such as, but not limited to, the handling of flammable chemicals. Cite 1910.132(a), for failure to provide and ensure the use of flame-resistant clothing necessary to protect employees from burns due to flash fires.
Cite 1910.132(b), for failure to ensure that employee-owned FR clothing is properly maintained and sanitary.
Cite 1910.132(c), for failure to provide FR clothing that is of safe design and construction for the work being performed. Refer to consensus standards such as NFPA 2112, Standard on Flame- Resistant Garments for Protection of Industrial Personnel Against Flash Fire, and NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire.
Click Here (pdf) for the entire directive.
Pipeline Accident Report: San Bruno, CA, Natural Gas Pipeline Explosion and Fire, September 9, 2010
Lessons we can apply to our Process Safety Management Systems
On September 9, 2010, about 6:11 p.m. Pacific daylight time, a 30-inch-diameter segment of an intrastate natural gas transmission pipeline known as Line 132, owned and operated by the Pacific Gas and Electric Company (PG&E), ruptured in a residential area in San Bruno, California. The rupture occurred at mile point 39.28 of Line 132, at the intersection of Earl Avenue and Glenview Drive. The rupture produced a crater about 72 feet long by 26 feet wide. The section of pipe that ruptured, which was about 28 feet long and weighed about 3,000 pounds, was found 100 feet south of the crater. PG&E estimated that 47.6 million standard cubic feet of natural gas was released. The released natural gas ignited, resulting in a fire that destroyed 38 homes and damaged 70. Eight people were killed, many were injured, and many more were evacuated from the area.
1910.119(j)(6) Quality assurance
The National Transportation Safety Board's investigation found that the rupture of Line 132 was caused by a fracture that originated in the partially welded longitudinal seam of one of six short pipe sections, which are known in the industry as "pups." The fabrication of five of the pups in 1956 would not have met generally accepted industry quality control and welding standards then in effect, indicating that those standards were either overlooked or ignored. The weld defect in the failed pup would have been visible when it was installed.
1910.119(n) Emergency planning and response
The rupture occurred at 6:11 p.m.; almost immediately, the escaping gas from the ruptured pipe ignited and created an inferno. The first 911 call was received within seconds. Officers from the San Bruno Police Department arrived on scene about 6:12 p.m. Firefighters at the San Bruno Fire Department heard and saw the explosion from their station, which was about 300 yards from the rupture site. Firefighters were on scene about 6:13 p.m. More than 900 emergency responders from the city of San Bruno and surrounding jurisdictions executed a coordinated emergency response, which included defensive operations, search and evacuation, and medical operations. Once the flow of natural gas was interrupted, firefighting operations continued for 2 days. Hence, the emergency response by the city of San Bruno was prompt and appropriate. However, PG&E took 95 minutes to stop the flow of gas and to isolate the rupture site - a response time that was excessively long and contributed to the extent and severity of property damage and increased the life-threatening risks to the residents and emergency responders. The National Transportation Safety Board found that PG&E lacks a detailed and comprehensive procedure for responding to large-scale emergencies such as a transmission pipeline break, including a defined command structure that clearly assigns a single point of leadership and allocates specific duties to supervisory control and data acquisition staff and other involved employees. PG&E's supervisory control and data acquisition system limitations caused delays in pinpointing the location of the break. The use of either automatic shutoff valves or remote control valves would have reduced the amount of time taken to stop the flow of gas.
1910.119(j) Mechanical integrity
PG&E's pipeline integrity management program, which should have ensured the safety of the system, was deficient and ineffective because it ----Was based on incomplete and inaccurate pipeline information (1910.119(d) Process safety information)
-Did not consider the design and materials contribution to the risk of a pipeline failure. (1910.119(e) Process hazard analysis)
-Failed to consider the presence of previously identified welded seam cracks as part of its risk assessment.
-Resulted in the selection of an examination method that could not detect welded seam defects. (1910.119(j)(4)(ii) Inspection and testing procedures shall follow recognized and generally accepted good engineering practices)
-Led to internal assessments of the program that were superficial and resulted in no improvements.
Several deficiencies revealed by the National Transportation Safety Board investigation, such as PG&E's poor quality control during the pipe installation and inadequate emergency response, were factors in the 2008 explosion of a PG&E gas pipeline in Rancho Cordova, California. (See Explosion, Release, and Ignition of Natural Gas, Rancho Cordova, California, December 24, 2008, Pipeline Accident Brief NTSB/PAB-10/01 (Washington, DC: National Transportation Safety Board, 2010)). This 2008 accident involved the inappropriate installation of a pipe that was not intended for operational use and did not meet applicable pipe specifications. PG&E's response to that event was inadequate; PG&E initially dispatched an unqualified person to the emergency, causing an unnecessary delay in dispatching a properly trained and equipped technician. The National Transportation Safety Board concluded that PG&E's multiple, recurring deficiencies are evidence of a systemic problem. The investigation also determined that the California Public Utilities Commission, the pipeline safety regulator within the state of California, failed to detect the inadequacies in PG&E's integrity management program and that the Pipeline and Hazardous Materials Safety Administration integrity management inspection protocols need improvement. Because the Pipeline and Hazardous Materials Safety Administration has not incorporated the use of effective and meaningful metrics as part of its guidance for performance-based management pipeline safety programs, its oversight of state public utility commissions regulating gas transmission and hazardous liquid pipelines could be improved. Without effective and meaningful metrics in performance-based pipeline safety management programs, neither PG&E nor the California Public Utilities Commission was able to effectively evaluate or assess PG&E's pipeline system. Click Here for more on this incident.
Barriers to Occupational Injury Reporting by Workers
Each year about 5,400 workers die from a work-related injury and 4 million private industry workers report a nonfatal injury or illness. There are 3.4 million workers treated in U.S. hospital emergency departments annually for nonfatal occupational injuries and illnesses. Although studies indicate that we have reduced the number of nonfatal injuries in recent decades, there is evidence that nonfatal occupational injury surveillance significantly underreports workplace injuries. This presumed undercount potentially decreases health and safety funding because of a false sense of improvement in the occupational injury rates. It also increases the misdirection of scarce safety and health resources because hazardous workplaces are not appropriately identified or assessed and intervention efforts cannot be properly targeted or evaluated. It is this basic need for reliable and comprehensive occupational injury surveillance that led to the 1987 National Academy of Science report Counting Injuries and Illnesses in the Workplace--Proposals for a Better System and the 2008 Congressional Report Hidden Tragedy: Underreporting of Workplace Injuries and Illnesses. The proposed pilot research addresses two facets of nonfatal occupational injury reporting noted in these reports--understanding barriers and incentives to reporting occupational injuries and using this knowledge to assess and improve our surveillance activities. The objectives of this project are to (1) characterize and quantify the relative importance of incentives and disincentives to self-identifying work-relatedness at the time of medical treatment and to employers; (2) characterize individual and employment characteristics that are associated with non-reporting of workplace injuries and incentives and disincentives to reporting; (3) test the reliability of hospital abstractors to properly distinguish between work-related and non-work-related injuries; and (4) evaluate the feasibility, need, and requirements for a future larger study. Results will be disseminated in multiple forms to reach a variety of occupational health and safety stakeholders. This project will use the occupational and the all injuries supplements to the National Electronic Injury Surveillance System (NEISS-Work and NEISS-AIP, respectively) to identify telephone interview survey participants. NEISS-Work and NEISS-AIP, collected by the Consumer Product Safety Commission (CPSC), capture people who were treated in the emergency department (ED) for a work-related illness or injury (NEISS-Work) or any injury, regardless of work-relatedness (NEISS-AIP). Interview respondents will come from two subgroups-- individuals treated for a work-related injury and individuals who were treated for a non-work-related injury but who were employed during the time period that the injury occurred.
Clarification on whether an exercise regime
is first aid or medical treatment
OSHA clarifies whether an exercise regime directed by a Certified Athletic Trainer (ATC) would constitute "first aid" or "medical treatment" for OSHA injury and illness recordkeeping purposes. In general, if the ATC recommends exercise to an employee who exhibits any signs or symptoms of a work related injury, the case involves medical treatment and is a recordable case. OSHA discussed the issue of therapeutic exercise in the preamble to the final rule revising OSHA's injury and illness recordkeeping regulation. See, 66 FR 5992, January 19, 2001. OSHA stated that it considers therapeutic exercise as a form of physical therapy and intentionally did not include it on the list of first aid treatments in Section 1904.7(b)(5)(ii). Section 1904.7(b)(5)(ii)(M) states that physical therapy or chiropractic treatment are considered medical treatment for OSHA recordkeeping purposes and are not considered first aid. Section 1904.7(b)(5)(iii) goes on to state that the treatments included in Section 1904.7(b)(5)(ii) is a comprehensive list of first aid treatments. Any treatment not included on this list is not considered first aid for OSHA recordkeeping purposes. Please be aware that if a treatment is administered as a purely precautionary measure to an employee who does not exhibit any signs or symptoms of an injury or illness, the case is not recordable. For a case to be recordable, an injury or illness must exist. For example, if, as part of an employee wellness program, an ATC recommends exercise to employees that do not exhibit signs or symptoms of an abnormal condition, there is no case to record. Furthermore, if an employee has an injury or illness that is not work-related, (e.g., the employee is experiencing muscle pain from home improvement work) the administration of exercise does not make the case recordable either. Your letter also requested specific guidance on several questions concerning the administration of exercise. For purposes of this response, we presume that all of the questions relate to the administration of exercise as a treatment for work-related injuries.
Tech Talk® Webinar covers flammable liquid storage
PLEASE NOTE: I am in NO WAY endorsing this webinar. I just know a lot of businesses struggle with flammable liquid safety and this may be a FREE opportunity to pick up some good info.
States Cracking Down on Drunk Drivers
September 2nd is the Second Most Deadly Day of the Year on Roadways
Drunk driving is not an accident--it's blatant disregard for human life. In 2009, nearly 11,000 people died in crashes in which a driver or motorcycle rider was at or above the legal alcohol limit. This is why GHSA's member State Highway Safety Agencies are joining forces with the U.S. Department of Transportation's National Highway Traffic Safety Administration (NHTSA) and local officials to conduct the national Drive Sober or Get Pulled Over Labor Day drunk driving crackdown. A full list of state-specific crackdown efforts is available on GHSA's website at: www.ghsa.org/html/projects/dd/otlua/laborday11.html. For current drunk driving laws, visit: www.ghsa.org/html/stateinfo/laws/impaired_laws.html. To view the announcement from the U.S. DOT, visit www.nhtsa.dot.gov.
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Safety and Health Tip
WISER for Android
Civilian Fire Fatalities
On August 31, 2011, 2 residential fire fatalities were reported by news media throughout the United States.
September 6-9, 2011
Sept. 13-16, 2011
September 14, 2011
Joint OSHA, LCCA, Abbott Safety Day
Sept. 22, 2011
OPEN to ALL
Topic is Subpart CC
October 25-27, 2011
College Station, TX
If you have a conference or an outing for your safety organization, let me now and I can help spread the message. And yes, posting is FREE!