PHMSA asking for feedback on "requiring water be the fluid for Hydro testing containers"
The battle continues, this time outside process safety! I get these arguments routinely when people inquire if they can use their HHC/EHS as the media for pressure and leak testing. I can only assume that PHMSA is getting pushback by requiring water or other similar viscosity liquid to be used as the test medium. When hydrostatic pressure tests for cargo tanks are required in part 180, subpart H, the HMR requires that water or other similar viscosity liquid be used as the test medium (see § 180.407(g)(viii)). PHMSA understands that some stakeholders believe the requirement to use water—or other similar viscosity liquid—may be unduly restrictive. PHMSA has authorized the use of alternate test mediums for portable tank testing (e.g., DOT SP–20294, 20308, and 16163), but has not authorized this for cargo tanks. PHMSA requests comment on the following questions to evaluate authorizing additional liquids for hydrostatic testing cargo tanks: Read more ... Add new comment
Pressure Testing GONE BAD (8" Pipe Failure)
Four employees were testing an 8" chiller pipe with pressure when a piping joint failed and an employee was struck in the shoulder and head by a valve cap. The employee was transported by ambulance to a Hospital. PRCS fatality - welding in ship under construction (oxygen-deficiency during welding)
On August 28, 2023, at 7:30 a.m., a worker was welding in a confined space on a ship under construction. The victim was found unresponsive inside of the confined space. Per the medical examiner's report, the employee was killed as a result of suffocation in an oxygen-deficient environment. NOTE: this is likely due to a shielding gas such as Argon being used in this welding. Source: https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1694074.015 OSHA addresses Compressed Gas cylinders on carts (OSHA LOI)
Your letter discusses concerns with the safety of compressed gas cylinders on some types of portable carts configured for “in use” or “connected for use.” Specifically, you mention that cylinders, which are top heavy and therefore can be unstable (unbalanced), are commonly found poorly secured to the cart and leave the cylinders susceptible to toppling over when used, moved, or stored. In your letter, several pictures are provided to illustrate your point (See Pictures 1, 2, and 3) of poorly secured cylinders. Question 1: Are acetylene cylinders positioned at a 45-degree angle from vertical, as shown in picture 4, acceptable to OSHA while in use, moved, or stored? Question 2: Are cylinder carts subject to the special design, and if so, please identify the standard.
CLICK HERE for the LOI (posted recently, but dated 2021)
Literally, what it LOOKS like to leave blind luck behind and embrace LEADING INDICATORS
I'm not asking for much, but before I leave this great and honorable profession, I just hope we can GET BACK TO THE FUNDAMENTALS! A great place to start would be to eradicate all these "Worked ____ Days" signs and progress to celebrate what got us those injury-free days. As I have said for decades... Too much reliance on BLIND LUCK is a dangerous thing. And far too many workplaces are celebrating BLIND LUCK with these old and tired signs. How often have you encountered one of these signs that is years out of date, dirty, and downright disgraceful in appearance? We must celebrate our hard work and dedication to safety, so celebrating achieving/exceeding our goals, based on LEADING INDICATORS, is how we MUST measure our success in safety. Don't get me wrong, injury-free days are something to celebrate - WHEN we know HOW we achieved them! Simply changing the number on a sign without having confidence that we KNOW HOW we are achieving those numbers will cause almost everyone to get too confident. And when confidence is high because of BLIND LUCK - BAD things will happen. And it just does not have to be this way! Embrace the shift to celebrating achieving LEADING INDICATOR goals and those days when the men and women doing the dirty and dangerous work go home in the same condition they arrived in!
Did NFPA make "30 seconds" the norm for "relaxation time"?
Did the 2024 edition of NFPA 77, Recommended Practice on Static Electricity establish a norm for "relaxation time"? In six (6) different sections across five (5) chapters, the recommended practice cites "30 seconds" as a "suitable precaution." (emphasis by me) Defining and Quantify when Shut Off Valves are necessary/required
How many of you have thought these two images would ever have a place in Process Safety? I use them as visual aids when teaching some of my RAGAGEP courses, as they place a mental image that most can grasp into the students' heads and provide them with a valid engineering metric they can use to ensure their HAZMAT bulk containers have adequate safeguards in their basic design. These metrics are used to QUANTIFY "connection sizes" on bulk tanks where "Shutoff Valves" and/or "Excess Flow Valves" would be required. A lot of folks never really think about the actual size of openings/connections that require a Shutoff Valve, so many are pretty surprised when they learn just how small the opening has to be and which connections require a Shutoff Valve. One such code reads... (emphasis by me) New HAZMAT exemptions (2024 IFC)
The 2024 edition of the International Fire Code has a new "table" that lists several exemptions. These exemptions come with some limitations, such as... Exempted materials and conditions listed in this table are required to comply with provisions of this code that are not based on exceeding maximum allowable quantities in Here are a few of the exemptions that may be of interest: 13 Brutal Truths Every Employer Needs to Know (Arpad Szakal, ACC)
This was NOT intended to be directed at safety, but damn, if we look at all 13 through the lens of "barriers to world-class safety," they sure do resonate. I have bolded my Top 3; which are your Top 3? 13 Brutal Truths Every Employer Needs to Know: Responding to "small releases"
Both OSHA and EPA require PSM/RMP facilities to include procedures for "responding to small releases" in their Emergency Action Plans
Most of my clients will utilize the following in their "procedures for handling small releases": OSHA issues Car-Seal citations (Relief Protection System)
29 CFR 1910.119(f)(1) The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information. |
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