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Many THANKS to our NEWEST and CONTINUED "Partners in Safety" for all their support!
I would like to announce a friend's new website where he is trying to provide an avenue for safety professionals to find work. Bill has put a lot of personal time and money into this platform, all in the hopes to help safety professionals. Mission Statement: To Connect Safety Freelancers, Companies and Safety Vendors together to get work done. Check it out...
Is a CUI inspection required for insulated vessels?
We see a lot about Corrosion Under Insulation (CUI) as it relates to piping, but we can not forget that the same failure mode can occur on vessels as well. API 510 spells out some ranges as to when we MUST consider the need for a CUI inspection on our vessel(s). API 510 Internal Inspection Frequency
Sorry for a lack of posts these last couple of weeks, they have been crazy with travel and work. But I wanted to follow-up on a lot of questions and comments I got regarding my "Internal inspections... of my pressure vessel??? We don't need no internal inspections" post a few weeks back. If your engineers/management is telling you that the vessel does not need (or require) an internal inspection then all we can do is provide the RAGAGEP facts and ask them to explain why not. I can tell you this, OSHA/EPA will take this minimal position as well. But for those of you that seek more info, here is what I have been sending SAFTENG subscribers and clients: WRONG CHEMICAL - WRONG RAILCAR (Reaction leads to Catastrophic Failure)
On June 3, 2019, a railcar catatrophically failed when incompatible materials stored inside the car reacted and approximately 20,000 gallons of liquid waste derived fuel – fuel derived from hazardous waste – spewed from the railcar for 34 seconds. The eruption sent waste fuel several hundred feet into the air and ripped the manway hatch from the railcar. The hatch came to rest approximately 370 yards from the railcar. Droplets of waste fuel traveled more than 1/3 of a mile, landing on buildings, structures and vehicles near the facility. Agitators in several tanks were not maintained in functional condition. The facility was blending and storing incoming loads of waste fuel in railcars. A system of analysis was not in place to ensure compatibility of the blended waste fuel.
CLICK HERE for the MSHA report. Hazard Assessment and Verification (1910.132(d) & (g))
Sometimes the OSHA "Request for public comments" postings contains some really good insights as to the documentation aspect to OSHA compliance. This week's posting does a nice job of explaining all that is required to document our PPE Hazard Assessments: (emphasis by me, but 100% OSHA wording) Paragraph 1910.132(d)(1) and the Personal Fall Protection standard REQUIRE... EPA RMP Citations @ explosives plant (NH3, HNO3, Oleum & $18K) w/ $69K SEP)
So this week we all got a chuckle when I posted this picture to my Social Media groups:
But in all seriousness, this is NO laughing matter! Well, we can at least surmise that EPA inspectors do not find the humor in it, as is evident in the nine (9) labeling issues they noted in this RMP inspection! From NFPA 704 Diamonds with differing degrees of hazards for the same chemical to faded labels such that the color-coding is no longer identifiable, to piping not being labeled per ASME A13.1, to the Ammonia storage tanks not being labeled per CGA 2.1-2014. Respondent operates a "stationary source" and has submitted and registered an RMPlan. The respondent has developed an RMProgram accidental release prevention program for the stationary source. At its stationary source, Respondent manufactures explosives and has on-site for use, approximately 609,000 pounds of anhydrous ammonia, 2,730,000 pounds of nitric acid, and 100,000 pounds of oleum. At its stationary source, Respondent has six RMProgram level 3 covered processes, which store or otherwise use anhydrous ammonia, nitric acid, and oleum in amounts exceeding their applicable threshold of 10,000 pounds, 15,000 pounds, and 10,000 pounds, respectively. On May 8-9, 2017, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing Respondent's compliance with the RMProgram requirements and the implemented recognized and generally accepted good engineering practices (RAGAGEP) for its covered processes at its stationary source. At the time of the inspection, Respondent had the following deficiencies: OSHA makes it clear - difference between controlling a hazard and eliminating a hazard
As our debate/discussion continues regarding falls within or into a Confined Space and if that fall hazard is one that makes the CS a PRCS and if a PRCS can be reclassified when there is a fall hazard present. I keep sharing OSHA language and it keeps being diced up and rephrased to meet personal agendas. Look, if anyone wants to manage the fall hazards via their entry permit system, I am in NO WAY saying you can not do it. What I am saying is that we need to stop laying claim that OSHA requires it. Granted, OSHA is the bottom of the proverbial safety barrel and as I have written many times, we MUST do better in safety than just meeting OSHA minimums. I have received countless e-mails and about 50% say a PRCS that contains a "fall hazard" can NOT be reclassified and surprisingly the other 50% danced around the idea that if the entrants were wearing personal fall arrest system (PFAS) that this would allow for the space to be reclassified. I still can not believe these arguments so many passionately defend, but to establish the fact that wearing a PFAS does NOT ELIMINATE the hazard, but merely controls the hazard. Thus if we treat a fall hazard as a "recognized serious safety and health hazard" that would prevent a PRCS from being reclassified to a non-PRCS; merely requiring the entrants (and/or attendants) to wear PFAS does NOT eliminate the hazard - which 1910.146(c)(7) requires ELIMINATION of the "hazards" which made the space a PRCS. Here is what OSHA had to say about "controlling" a hazard and "eliminating" a hazard as it relates to confined spaces... EPA's RMP Vulnerable zone determination
EPA RMP Citations @ meat processing facility (NH3 & $10K)
Respondent is the owner or operator of a meat processing facility. On March 8, 2017, an authorized representative of the EPA conducted a compliance inspection of Respondent's Facility to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.F.R. Part 68 under section 112(r)(7) of the Act. Based on the March 8, 2017 inspection, the EPA has determined that Respondent violated those regulations as stated below. NOTE: It is odd that this level of deficiencies resulted in only a $10,000 fine. The CAFO makes no mention of a SEP or factors that would have resulted in such a low dollar amount. Can we extend the life of our SCBA cylinders using Modal Acoustic Emission (MAE) Examination
In the last couple of years we have come across a vicious and BADLY MISLEADING rumor that some facilities have fallen for and thus they have fallen out of compliance with OSHA/NIOSH/DOT in regards to their SCBA Cylinders. FACT: There are studies that have been done by the U.S. Navy and PHMSA that demonsrate 15-year service life is very conservative and with a different type of testing, the cylinders service life could be safely extended. LIE: A facility can adopt Modal Acoustic Emission (MAE) testing and extend their cylinders service life based on the test results. There is a LOT MORE to these studies and we can NEVER wander away from the cylinder's and/or the holder of the NIOSH approval "maintenance requirements". Here is a look at the studies and how we got to this point. BUT BEWARE... we MUST STILL FOLLOW the cylinder manufacturer or the NIOSH certificate holder's test frequency for their cylinders! We are NOT allowed to adopt Modal Acoustic Emission (MAE) as an alternative to Hydrostatic Testing WITHOUT WRITTEN APPROVAL from... Another solvent applied in lift station PRCS Fatality (Acute MEK toxicity)
At 11:45 a.m. on August 28, 2012, an employee was finishing a painting assignment to coat pipes in six confined spaces at a lift station site. The employee was cleaning the pipes using a Methyl Ethyl Ketone (MEK) solvent prior to applying a two-part epoxy paint that contained Xylene, Methyl Isobutyl Ketone (MIBK), and Ethyl Benzene. The employee's supervisor saw him entering the site and later found the employee unresponsive at the bottom of the manhole where he was working. The supervisor called 911 and emergency responders pronounced the employee dead at the scene. |
2019 Training Calendar
24-Hr HAZMAT Tech @ Client in Northern KY 9/10 - 9/12/2019
Intermediate Process Safety 3-Day Course (CAT 1 Flammable Gas) @ Client in Ohio 9/16 - 9/18/2019
2-Day PHA Refresher What-If & HAZOP @ Client in Ohio 9/19 - 9/20/2019
Advanced Process Safety 5-Day Course NH3 in SCR @ Power Plant in IN 9/30 - 10/4/2019
24-Hr HAZMAT Tech @ Client in KY 10/15 - 10/17/2019 Hybrid HAZMAT/Process Safety Chlorine 1-ton Cylinders NY State 11/11 - 11/15/2019
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One way EPA selects facilities to be inspected is by "Vulnerable Zones". These are areas that could be affected by a release from a chemical accident at a facility subject to the risk management program requirements in 40 CFR Part 68. So how can a facility determine if they are one of the many facilities that impact a "vulnerable zone" and is higher on the "radar" list EPA uses to establish inspection frequencies?
