Contractor's scissor lift causes NH3 release
On October 19, 2019, @ 07:15 a.m., a contractor employee was standing on a scissor lift and replacing insulation on the pipes in the engine room of Building 3. As the employee lowered the scissor lift, the walking platform of the scissor lift where a technician was standing struck the service drain valve (3ML 3064) and cracked the nipple at the thread, causing an uncontrolled release of pressurized anhydrous ammonia. Membership Content
Talking management's language in managing safety
One of the more widely found complaints regarding safety professionals is that "they don't talk about safety in terms that management can understand/embrace." Personally, as a safety professional, I find that an easy excuse not to embrace safety MANAGEMENT, but I may be a bit biased since I am a safety professional and I have never had a management group accuse me of such nonsense. But as a consultant, I have heard that phrase many times; hence why I refer to my SMS as a "Safety Process." In 1996, I learned all about Statistical Process Control (SPC), which was the mother of Six Sigma, which I fully embraced and eventually became a Black Belt in Six Sigma. This tool was a perfect fit for making safety part of a daily function within everything at a facility. The Six Sigma model is DMAIC: This model/approach can be a significant first step toward LEADING INDICATORS. The model is exactly what each stage says: Episode 122 - Bryan Haywood - Permit and Non-Permit Required Confined Spaces
This was a brief 30-minute chat with my friend and longtime supporter @ SAFTENG on the topic of Permit-Required Confined Spaces. This first episode was just the basics, but I explain how a confined space is DEFINED and how that confined space becomes a Permit-Required Confined Space (PRCS). We then discuss the three (3) entry options: (c)(5), (c)(7), and (d)-(k), and many of the pros and cons that come with each entry option.
Possible Catastrophic Failure of Nurse Tanks and Recommendation for Periodic Testing February 2024 (FMCSA Safety Advisory)
The Federal Motor Carrier Safety Administration (FMCSA) and the Pipeline and Hazardous Materials Safety Administration (PHMSA) issue this safety advisory to provide notice of the possibility of catastrophic failure of certain hazardous materials packages commonly known as “nurse tanks.” See Title 49, Code of Federal Regulations (49 CFR) §173.315(m). This notice focuses on nurse tanks manufactured from January 1, 2007, through December 31, 2011, by American Welding and Tank (AWT) at its Fremont, Ohio plant. Nurse tanks manufactured by AWT from 2009 to 2010 were the subject of a prior FMCSA investigation and enforcement action in response to improper manufacturing procedures. On August 23, 2023, a 2009 AWT nurse tank containing anhydrous ammonia experienced a catastrophic failure in a farm co-op lot. The failure caused the tank shell to “rocket” over 300 feet from its original location. While no injuries were reported, this event is an indicator of potential continuing problems with AWT nurse tanks that have now been in service for over a decade. PRCS fatality - Tanker Truck (oxygen-deficiency during cleaning)
For those who believe entering a PRCS would not happen when the Oxygen level is measured at 19.5% (IDLH for O2 Deficiency)... November 22, 2022, @ 1:00 p.m., an employee from a local chemical company was cleaning the inside of a tanker trailer. The employee was required to enter the tank and wash out the tank with soap and water. Before entry, the oxygen level in the tank was 19.5%. The employee entered the tank and began his cleaning process. An attendant monitored the employee in the tanker but briefly stepped away to get another coworker to replace him. What does it mean to comply with 1910.147 vs. having a "management system" for Energy Control
Last month, I discussed what a "management system" would look like should we manage our Permit-Required Confined Space entry operations as a "management system" versus a standalone OSHA compliance program. (CLICK HERE for that post) Today, I want to discuss the same approach but in respect to how we manage another life safety critical practice... The Control of Hazardous Energy is better known as Lockout/Tagout (LOTO). As of this writing, I have written about LOTO 187 times, most of which are on the technical side of developing, implementing, managing, and auditing LOTO programs and procedures. In this article, I want to take a 35,000-foot view of how a an Energy Control Program should be managed by those closest to the action. So here is the outline of what I will be discussing: 1) Written Program 2) Machine/Equipment specific energy control procedures 3) Training 4) Periodic Inspections 5) Auditing And, of course, I will again use the PLAN→DO→CHECK→ACT model to wrap our heads around this topic. CHANGE… to improve safety (Administrative vs Engineering Controls)
A recent story in my local news was regarding changes to traffic patterns made to the 44th most dangerous intersection in OH. A 2018 traffic study showed there had been 114 crashes at the intersection over the previous four (4) years; 40% of those resulted in an injury. The state tried just about every administrative control known to man to reduce the number of accidents and their severity. Signs, and I mean BIG signs, warning of the dangerous intersection. Flashing caution lights on approaching the intersection when the lights were turning yellow and red. Reduced speed limit in the approach to and in the area of this intersection. All of these attempts using administrative controls had minimal impact on reducing accidents. The state did see a slight decrease in severity; however, the study could not correlate the reduction in severity to any of the administrative controls. So the state spent nearly $3M to redesign this intersection with a Restricted Crossing U-Turn (RCUT). And, of course, the news reporters could not find anyone who liked the change... Local 12 spoke with more than a dozen people at the gas station next to this intersection to see what they thought about the change. Not surprisingly, None of them liked it. Their responses ranged from "it's too complicated and confusing" to "it's more dangerous than before." Knowing the limitations of the respirator is CRITICAL
As is evident by several Permit-Required Confined Space incidents over the years, workers MUST FULLY understand the limitations of the respirators they are using. This latest incident involved a worker who was vacuuming, and the nozzle became stuck inside the tank. To free the nozzle, the worker—wearing a respirator with organic filters used explicitly for working outside the tank—fully entered the tank, where he went unconscious. Coworkers found the worker inside the tank lying under the fluid. Cardiopulmonary Resuscitation (CPR) was administered to revive the worker. A comprehensive investigation revealed: Emergency Use Only SCBA and 90% Full
This week, I conducted a 24-hr HAZMAT Tech course for a client. The facility had purchased some new SCBA cylinders, and we noticed an odd difference between two of the cylinders. One cylinder was manufactured in 2021, and one was manufactured in early 2022, just six months apart. As I was covering the requirements for "Emergency Respiraors" to be 90% full BEFORE they can be used in an emergency, one of the students asked, "How do we do that?" The cylinder gauge he looked at would have had an experienced responder asking the same question! Here is what OSHA's standard states: (emphasis by me)
Employer failed to address 3rd party OSH audit findings ($348K)
This is an interesting "press release" from OSHA. Although OSHA has a "policy" not to use audits and inspections performed within the facility to issue citations against, when the employer does NOT address the hazards identified in the inspections and audits, OSHA can take issue with this failure to abate. This is what seems to have happened here. A complaint initiated the inspection. OSHA cited a steel fabrication business after finding the company willfully exposed workers to safety and health hazards at its Millville shop. OSHA issued four willful and seven serious violations and proposed $348,683 in penalties. The agency's investigation began on July 26, 2023, in response to a complaint. "A few months before our inspection, the facility hired a safety consultant who identified multiple safety and health hazards at the Millville fabrication shop. However, the company failed to correct the hazards, which is unacceptable" (OSHA Area Director) Is safety like bags of chips... half full of air?
Unfortunately, this economic image reminds me of some “safety programs” I have come across in my travels... The “program” looks great, sitting on the shelf in the fancy, shiny binder.
But once we open the binder/package, we find a lot of “fluff” (i.e., air)!
Let’s be serious… Safety is not a marketing or PR exercise of pumping the workforce with fancy slogans and banners around the facility.
It is a CONTINUOUS exercise we do WITH the men and women who do the dirty and dangerous work, which, by the way, is done 100% for those same men and women.
The value the business gets from this PARTICIPATION in the safety process/SMS is priceless in terms of safety performance and culture, as well as reduced costs of injuries and business interruptions. We can equate these safety and culture improvements to a business's bottom line.
But it takes more than a binder/bag half full of air sitting on a shelf looking pretty! |
Partner Organizations
I am proud to announce that The Chlorine Institute and SAFTENG have extended our"Partners in Safety" agreement for another year (2024) CI Members, send me an e-mail to request your FREE SAFTENG membership
Member Associations
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