Lack of Quality Control (QC) regarding "diesel test fuel" leads to fatal explosion ($680,000)
On January 13, 2022, workers inside the company’s fabrication shop performed a "wet test" on a newly built tank truck to check for leakage. This entailed running diesel test fuel through different tank compartments and other truck components. This was a routine operation at the workplace. Workers knew never to use gasoline, and the company had a standard operating procedure that prohibited gasoline or any tanker truck containing gasoline from entering the fabrication shop. The diesel test fuel was stored in a tank outdoors. An Ontario Fire Marshall investigation found that the gasoline involved in the explosion resulted from the use of CONTAMINATED diesel test fuel in the "wet test." Membership Content
Operating above the solution's Flash Point
I have written several articles on the topic of when we store our flammable liquids BELOW their flash points with the aid of refrigeration and how that makes our "refrigeration/chiller" a critical utility if we wish to take credit for storing the flammable below its FP. I have also discussed processing a Class IIIB/Cat 4 flammable liquid within 30 degrees of its FP. However, this article is about a "utility process" used for heating a process, and the heat transfer fluid (HTF) is heated above its FP. This process and analyzing its hazards can be tricky. When we look at the Safety Data Sheets and the Technical Datasheets, these fluids are almost always listed as "Non-Flammable" as their FPs are well over 200F. So at standard temperature and pressure (i.e., 68°F and 14.7 psi), the solution is indeed NOT flammable; however, we will be heating the solution to above its FP. This is a recognized hazard by OSHA, Insurance Providers, and NFPA; which insurance and NFPA 30 provide the user(s) some excellent DESIGN features to help PREVENT a LOPC event and PROTECTION and MITIGATION layers when the LOPC event occurs. First and foremost, codes and standards manage these hazards by setting a tolerance against operating up to 30 degrees within the solutions FP. How do you define the scope of "Authorized Employees"
Managing our LOTO program requires considerable resources, and it requires a team approach! However, we see many failed attempts to control hazards through a facility's LOTO program. One of the most common failures is how "authorized employees" are defined in terms of the skills they are trained on. Which Rabbit Hole you choose to go down and how far you go down depends on the payback we get from our efforts. How does your facility manage its authorized employees, and how does it go about "training" them to become "authorized employees"? For example, can any authorized employee lock out any machine/equipment in the facility, or is the program management MORE specific? Scenario:
Guarding comes BEFORE LOTO
I put this image together for a friend struggling to demonstrate to their management that we can not discuss LOTO until Machine Guarding is in place. These two topics go hand in hand and trust me; if there are guarding issues, those hazards will be compounded when we attempt to frame up the LOTO program. Guarding is for the OPERATIONAL safety of the machine/equipment and, if not done well, poses a big, if not bigger, risk to the workers running the machine/equipment. We routinely encounter serious guarding issues while helping clients with their LOTO efforts, and we are almost always told, "Thanks, but we just want help with LOTO." Controlling hazardous energy sources (e.g., LOTO) during maintenance and servicing is just as critical but entirely different from guarding. Just look at the scope/application of OSHA's 1910.147: (emphasis by me) World’s largest automotive supplier, 10 LOTO instance-by-instance citations
An Ohio subsidiary of one of the world’s largest automotive suppliers could have prevented a 26-year-old employee in Franklin from being fatally crushed in October 2023 if the company had provided proper machine guarding. OSHA responded after being informed of the incident and learned the worker, on the job for about a year, was placing cardboard under a machine that bends vehicle exhaust pipes when the incident happened. OSHA issued 10 instance-by-instance citations after finding the company did not properly train employees — including temporary workers under the company’s control — in lockout/tagout procedures. OSHA also issued a machine guarding violation. Investigators determined the employer failed to include detailed steps for lockout/tagout procedures, test its safety procedures annually and guard machines adequately. Based on these alleged violations, the company exposed machine operators to struck-by and caught-between hazards. In 2022, the agency cited the company for similar violations at the same location. The company faces $314,555 in proposed OSHA penalties for its recent infractions. The International Fire Code is an EXCELLENT resource
Are you tired of playing the OSHA Compliance game that requires us to "comply" with standards that are 50 years old? The International Fire Code (IFC) is an excellent resource for taking your hazardous materials handling systems/processes to the next level. The IFC is used or adopted in 42 states, including the District of Columbia, Guam, Puerto Rico, and the U.S. Virgin Islands. This means that most states can enforce the code requirements but rarely do. But this is NOT about complying to make the government happy! It is about advancing our level of safety through enhanced ENGINEERING CONTROLS and DESIGN for our hazardous materials systems and the safety systems we rely on when we have an incident. I have believed in this Code since the start of my career when I worked in a state that enforced its Fire/HAZMAT code, and we got regular inspections by the Authority Having Jurisdiction (AHJ). Hence, I have written or referenced the IFC in over 500 articles on SAFTENG. The ICC offers FREE Access to their codes: CLICK HERE SAFTENG Members can download my training presentations on some of the requirements from this code. Get to know your STKY chemicals (Asphyxiants)
There are two (2) types of Asphyxiants:
These different types of asphyxiants behave differently and cause harm differently. Get to know your STKY chemicals (Cl2)
Chlorine is EXTREMELY HAZARDOUS, with an IDLH of 10 ppm and a TLV of 0.5 ppm (just above the odor threshold for most). Chlorine is heavier than air (VD > 2.5), and when released, it forms a greenish-yellow gas with a pungent, irritating odor that follows the terrain at ground level. The mean odor threshold for chlorine lies between 0.2 and 0.4 ppm. Chlorine is a NON-FLAMMABLE gas; however, it is a powerful oxidizing agent, reacting explosively or forming explosive compounds or mixtures with many common chemicals. Chlorine immediately reacts with both organic and inorganic materials it comes into contact with to form chlorides. The primary route of exposure is INHALATION. Chlorine is very volatile, with a Boiling Point of -29°F. So, although it is shipped as a liquefied gas under pressure, once the primary containment is breached, it will quickly become a GAS. The Vapor Pressure of Cl2 is 6,450 mm hg @ STP. Remember, BP and VP have inverse relationships. As BP goes down, VP goes up, and vice versa. An excellent standard to follow is that water at STP has a VP of 25 mm hg and a BP of 212°F. Cl2 is the opposite: it has a high VP (6,450 mm hg) and a Low BP (-29°F).
The Protective Action Distance makes sense when you see this
An image from my HAZMAT courses... People wonder why the ERG Protective Action Distance diagram is shaped like it is. This image validates the model...
NOTE: Cl2 release image is from the Jack Rabbit testing project Human Factors in incident investigations assessment tool
Here is a GREAT "self-assessment" tool, just eight (8) questions, to evaluate your facility's ability to investigate and perform causal analysis properly. Appeals Court sides with Paper Mill over Confined Space incident
This is a crazy case! The mill hired a contractor to build scaffolding inside one of its Chlorine Dioxide (CLO2) tanks. The mill prepped the tank and even performed the initial air sampling of the space. Turned it over to one of the scaffolding contractor employees who would be the attendant for the entry. Three entrants and the attendant were wearing personal Cl2 air monitors. Three scaffolding builders entered the tank. After 30-40 minutes, one of them felt ill and exited the tank. Once outside his personal detector alarmed. Soon after, the other two workers' detectors went into alarm, and they exited the tank. Two entrants were hospitalized for two (2) days; the other two were treated and released. The employee who filed the suit continued to suffer symptoms from chlorine dioxide exposure, including excessive coughing and wheezing. He was diagnosed with bronchiolitis obliterans and upper airway injuries. He sued the mill, the company that made the personal detectors, and the company that supplied the detectors. So far, he has lost his case. This was his appeal, but it did not go well. The paper mill claimed they had no control over the event, even though it was their tank on their property. This post is NOT about limiting liability but about managing PRCS entry hazards. I will note that the meters' manufacturer presented evidence that two of the monitors detected chlorine dioxide limits that would have put them into alarm, but the monitors were switched off less than two minutes later. This happened several times over 24 minutes for one monitor and 33 minutes for the other. As noted above, their final inspection of the monitors before they were sold to the rental company had low alarm settings at 0.10 ppm and high alarm settings at 0.20 ppm. By the time of the incident, the settings had been changed to 0.20 ppm and 0.50 ppm. Safway employees stated that they had not changed the settings. The presumption is that the rental company changed them. Here is all the legal wrangling! |
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