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. Read more ... Add new comment
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! Make safety data as coveted as financial data
Why is it that safety metrics always get such a bad wrap? We hear the voices from the back of the room... "what gets measured, gets manipulated," so the outcry is that somehow measuring safety (other than the regulatory lagging indicators) is a waste of time and misleading. The funny thing is I never hear anyone decrying all the business's financial metrics, leading or lagging! If someone is caught manipulating those financial metrics, they can be criminally charged, and it happens FREQUENTLY at varying degrees (visit the USDOJ news release page). Yet, I have not heard the outcry from the back of the room to end all the financial business metrics, leading or lagging. Instead, we hold those who manipulate the financial metrics ACCOUNTABLE with consequences for their actions. In some cases, when this fraud impacts the general public, there may be new government legislation put in place to VALIDATE (e.g., inspect and audit) those metrics in "publically traded" businesses. So here is the hard truth... MEASURE "safety" using the same means and methods we use to measure the financial health of the business. Those manipulating safety data will be held accountable to the same level as those found manipulating the financial data. If we think this is fairy tale thinking... remember that the banner we drove by coming into the plant this morning did not state that "Financials are number 1". FRA requiring Emergency Escape Breathing Apparatus (EEBA) on some locomotives
FRA is amending its regulations related to occupational noise exposure in three (3) ways. Special NOTE: although I agree with this new requirement, it will be virtually impossible for the railroads to comply by March 2024. There are NOT enough EEBAs in inventory to supply the Class 1s. Then there is the written program and training that has to be put in place, and one month is impossible if we want to do it RIGHT.
The power of a vacuum (Flammable Liquid Storage Tanks)
I see far more damage to atmospheric storage tanks from vacuums than I do from over-pressure events. In almost every case, the tank had undergone a "change" that created the conditions for a vacuum to occur. And once we have a pressure differential with a lower pressure inside the tank than the atmospheric outside the tank, the atmosphere will simply collapse the tank. The tank is NOT being "sucked in"; it is being crushed from the 14.7 pounds per square inch of atmospheric pressure. Now, we need to take measures to ensure we do not CREATE this pressure differential inside the tank. This differential can be caused by a number of processing/design errors, with the most common being "vent too small." But we are in luck; a 50-year-old OSHA standard offers us some basic design requirements. The trick is MANAGING CHANGES to these tanks when they are OUTSIDE of the PSM standard! Here is what OSHA says about vent sizing for NORMAL and EMERGENCY operations. (emphasis by me)
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