In this week’s Newsletter
- REMINDER: Post your OSHA Log Annual Summary by February 1st
- FY 2011 - Top 10 Federal Standards with the Most “Repeat Violations” Cited
- NFPA 30 offers some GREAT facility siting for NEW process vessels
- Calling the National Response Center
Side Bar Items:
- SAFTENG Blog & SAFTENG LinkedIn Forum
- Safety and Health Tip – Metal Scaffold Board ALERT
- Civilian Fire Fatalities
- Safety Recalls
- EHS Events
REMINDER: Post your OSHA Log Annual Summary
by February 1st
How do I complete the annual summary?
- Total the columns on the OSHA 300 Log (if you had no recordable cases, enter zeros for each column total); and
- the calendar year covered,
- the company's name,
- establishment name,
- establishment address,
- annual average number of employees covered by the OSHA 300 Log, and
- the total hours worked by all employees covered by the OSHA 300 Log
NOTE: If you are using an equivalent form other than the OSHA 300-A summary form, as permitted under § 1904.6(b)(4), the summary you use must also include the employee access and employer penalty statements found on the OSHA 300-A Summary form.
How do I certify the annual summary?
A company executive MUST CERTIFY that he or she has examined the OSHA 300 Log and that he or she reasonably believes, based on his or her knowledge of the process by which the information was recorded, that the annual summary is correct and complete. Who is considered a company executive? The company executive who certifies the log MUST be one of the following persons:
- An owner of the company (only if the company is a sole proprietorship or partnership);
- An officer of the corporation;
- The highest ranking company official working at the establishment; or
- The immediate supervisor of the highest ranking company official working at the establishment.
How do I post the annual summary?
You MUST post a copy of the annual summary in each establishment in a conspicuous place or places where notices to employees are customarily posted. You MUST ENSURE that the posted annual summary is NOT ALTERED, DEFACED, orCOVERED by other material.
When do I have to post the annual summary?
You must post the summary no later than February 1 of the year following the year covered by the records and keep the posting in place until April 30.
FY 2011 - Top 10 Federal Standards with the Most
“Repeat Violations” Cited
1. 1926.501 – Fall Protection
2. 1926.451 – Scaffolding
3. 1926.652 – Excavations, Protective Systems
4. 19101200 – Hazard Communication
5. 1910.147 – Lockout/Tagout
6. 1910.305 – Electrical, Wiring Methods
7. 19261053 – Ladders
8. 1910.212 – Machine Guarding
9. 1910.303 – Electrical, General Requirements
10. 1926.453 – Aerial Lifts
Visit SAFTENG.net to see the other breakdowns of the 2011 OSHA Citations:
NFPA 30 offers some GREAT facility siting
for NEW process vessels
Anyone involved with PSM/RMP knows about "facility siting" and all the attention it has gotten since the Texas City, TX incident in 2005. Many companies struggle with this type of analysis, so I am passing along some great data that could be used during an expansion project at an existing facility or for a new facility. PLEASE note that even if your process does NOT fall under PSM or RMP, this data should still be used as many states use NFPA 30 (or some version) as their flammable liquid code. Chapter 17 is for "Processing Facilities" and the two sections that are most helpful are 17.3 and 17.4. Here are the applicable parts of these sections:
17.3 General Requirements.
17.3.1 Liquid processing operations shall be located and operated so that they do not constitute a significant fire or explosion hazard to life, to property of others, or to important buildings or facilities within the same plant.
17.3.2 Specific requirements shall depend on the inherent risk in the operations themselves, including the liquids being processed, operating temperatures and pressures, and the capability to control any liquid or vapor releases or fire incidents that could occur.
17.3.3 The interrelationship of the many factors involved shall be based on good engineering and management practices to establish suitable physical and operating requirements.
17.3.4 – 17.3.6 ... N/A
17.3.7 When a process heats a liquid to a temperature at or above its flashpoint, the following shall apply:
(1)The process vessel shall be CLOSED to the room in which it is located and VENTED to the outside of the building.
(2)If the vessel needs to be opened to add ingredients, the room ventilation shall meet the requirements of Section 17.11 and the process heating controls will be interlocked with the ventilation such that the process heat will shut down if the ventilation fails or is turned off.
(3)The process vessel shall be equipped with an excess temperature control set to limit excessive heating of the liquid and the subsequent release of vapors.
(4)If a heat transfer medium is used to heat the liquid and the heat transfer fluid can heat the liquid to its boiling point on failure of the process and excess temperature heat controls, a redundant excess temperature control shall be provided.
17.4 Location of Process Vessels and Equipment.
17.4.1 ... N/A
17.4.2 Processing vessels and buildings containing such processing vessels shall be located so that a fire involving the vessels does not constitute an exposure hazard to other occupancies.
17.4.3 The MINIMUM DISTANCE of a processing vessel to a property line that is or can be built upon, including the opposite side of a public way; to the nearest side of a public way; or to the nearest important building on the same property shall be one of the following:
(1) In accordance with Table 17.4.3
(2) Determined by an engineering evaluation of the process, followed by application of sound fire protection and process engineering principles
17.4.4 Where process vessels are located in a building and the exterior wall facing the exposure (line of adjoining property that is or can be built upon or nearest important building on the same property) is greater than 25 ft (7.6 m) from the exposure and is a blank wall having a fire resistance rating of not less than 2 hours, any greater distances required by Table 17.4.3 shall be permitted to be waived. If the exterior wall is a blank wall having a fire resistance rating of not less than 4 hours, ALL DISTANCES required by Table 17.4.3 shall be permitted to be waived.
17.4.5 All the distances given in Table 17.4.3 shall be DOUBLED where protection for exposures is not provided.
17.4.6* Liquid-processing equipment, such as pumps, heaters, filters, and exchangers, shall NOT be located closer than 25 ft (7.6 m) to property lines where the adjoining property is or can be built upon or to the nearest important building on the same property that is not an integral part of the process. This spacing requirement shall be permitted to be waived where exposures are protected in accordance with 17.4.3.
17.4.7 Processing equipment in which unstable liquids are handled shall be separated from unrelated plant facilities by either of the following:
(1) 25 ft (7.6 m) clear spacing
(2) A wall having a fire resistance rating of not less than 2 hours and explosion resistance consistent with the expected hazard
17.5 Accessibility. Each process unit or building containing liquid-processing equipment shall be accessible from at least one side for fire fighting and fire control.
Calling the National Response Center
Who at your place of business calls the National Response Center after your business has experienced a chemical incident? Not many people have ever had to call this center (luckily!) but if your business ever does have a "reportable release” a call just like this one MUST BE MADE within 30 minutes after you have determined that the release exceeds the "Reportable Quantity".
CLICK HERE for more on EPA's Reportable Quantities. Garden City Ammonia Program group did this drill call with the NRC so we can hear firsthand how the call will be handled and the questions that will be asked.
I want to point out a VERY SERIOUS matter that you will hear in this drill call... HEADCOUNT is a MUST HAVE when making this call. The NRC is well aware that you will be dealing with this incident first and then calculating the amount released. A facility should WITHOUT A DOUBT be able to obtain an accurate headcount by the time this call is being made. If you do not, you have serious troubles coming your way!!! You will notice, even though this is a drill call, her tone changes when she ask for the headcount number and the instructor stated it was under way.
MANY THANKS to the team at Garden City Ammonia Program for doing this drill call! Click Here to listen to the call.
More about the NRC...
The NRC maintains a 24-hour-per-day, 7-day-a-week, 365-day-a-year Operations Center where all information is
- received via the toll-free number -- (1-800-424-8802)
- entered directly into an on-line data base system, and
- electronically disseminated as part of the National Response System.
Once contacted, the NRC Duty Officer will guide the caller through a detailed series of questions based on the Standard Report Form to gather as much information as possible concerning the spill or release. Standard Report Forms are also available on-line at http://www.nrc.uscg.mil/reporttxt.htm. The information is immediately entered into the Incident Reporting Information System (IRIS) and based on several pre-established criteria including material involved, mode of transportation, injuries, damage, and fatalities, select federal agency notification will take place within 15 minutes of receipt. When any of the following incidents occur, the NRC should immediately be contacted by the responsible party via the toll free number. If you see or discover an oil spill or release of chemicals and are NOT the responsible party, you should contact the NRC with whatever information you have.
Section 311(b)(5) of the Federal Water Pollution Control Act, Section 306(a) of the Outer Continental Shelf Lands Act Amendments of 1978, and Section 16(b) of the Deepwater Ports Act of 1974, require that the responsible party notify the National Response Center as soon as knowledgeable of an oil spill from a vessel or facility operating:
- In or along U.S. navigable waters;
- On the Outer Continental Shelf;
- In a deepwater port; or
- From a vessel transporting oil from the Outer Continental Shelf
The Comprehensive Environmental Response, Compensation, and Liability Act (CRCLA) requires that all releases of hazardous substances (including radionuclides) exceeding reportable quantities, be reported by the responsible party to the National Response Center. Title 40 of the Code of Federal Regulations Part 302 promulgates reportable quantities and reporting criteria. All the Extremely Hazardous Chemicals (EHS) which overlap with the CERCLA listed chemicals table (40 CFR Part 302.4) should be reported to NRC as well as to the LEPC and SERC.
Transportation accidents involving hazardous materials, including radioactive substances, must be reported to the National Response Center immediately by the carrier when, as a direct result of the materials:
- A person is killed;
- A person receives injuries requiring hospitalization
- Property damage exceeds $50,000; or
- Fire, breakage, or spillage of an etiologic agent occurs.
Further details can be found in 49 CFR 171.15.
Liquid Pipeline Releases
The responsible party must call the National Response Center when a pipeline system failure releases a hazardous liquid or carbon dioxide which causes any of the following:
- An explosion or fire;
- An escape to the atmosphere of more than five barrels a day of highly volatile liquid or carbon dioxide;
- A death or injury;
- Property damage exceeding $50,000
- Pollution of any body of water; or
- An incident deemed significant by the operator
Further details can be found in 49 CFR 195.52.
Gas Pipeline Releases
Releases of any toxic, corrosive or flammable gas, liquefied natural gas (LNG) or gas from an LNG facility must be reported to the National Response Center by the responsible party when:
- A death or injury involving patient hospitalization occurs;
- More than $50,000 damage occurs (including cost of lost gas)
- The release results in the emergency shutdown of an LNG facility; or;
- An incident is deemed significant by the operator.
Further details can be found in 49 CFR 191
Discharges from a hazardous waste treatment or storage facility must be reported by the emergency coordinator at the facility. Abandoned dump or waste sites should be reported by anyone having knowledge of such a site.
Try this "Fixed Incident" TEST REPORT to get your feet wet. A FIXED Incident is the widest ranging incident type and includes the release of material from non-mobile machinery, refineries, manufacturing plants, and numerous other fixed facilities. By the way, the is the EXACT INFORMATION you will need when calling the NRC, so this test form could be used as your internal data collection form BEFORE making the call.