NASA's Dirty Dozen
The Dirty Dozen highlights the most frequently observed human-related issues discovered during Fiscal Year 2022 agency mishaps and close-call investigations. Throughout the year, these issues contributed to $3,310,298.74 in damage costs and 630 workdays of lost time. Membership Content
NASA's Human Factors Analysis and Classifications System (HFACS)
In Reason’s Swiss Cheese model, there are four “slices "or tiers of human error potential, divided into two sections: an “active” layer and “Latent Factors”: preconditions, Supervision, and Organization. The goal of the Human Factors Analysis and Classification System (HFACS) is to understand human factors throughout the system rather than stopping at the operator. Most mishaps can be connected to human events at NASA, from 2010-2015, human events and conditions totaled 79% of causal factors identified in its mishaps and close calls. Consequently, NASA now requires the participation of a Human Factors Investigator in Type A & B mishaps and High Visibility Close Calls. These are Influences or Factors closely tied to the mishap and described as actions or inactions that result in a mishap. There are four (4) areas in this active layer, and these are: CSB's Accidental Release Reporting (40 CFR 1604)
This is a reminder that if your ERP or Environmental Management System (EMS) has not been updated to reflect these "NEWER" CSB reporting requirements, the facility should consider updating these programs/processes and including the reporting requirements in EHS training. Also, line 9.8 of your RMP should list 40 CFR 1604 - Accidental Release Reporting. The U.S. Chemical Safety and Hazard Investigation Board (CSB) has launched investigations into toxic chemical releases at two facilities in Louisiana during 2023: the release of hydrogen fluoride (HF) and chlorine at a facility in Geismar, LA, in January 2023 and the release of ethylene oxide (EtO) at the a facility in Plaquemine, LA in July 2023. Both incidents were reported to the CSB in accordance with the agency’s Accidental Release Reporting Rule (40 CFR Part 1604). Changes to Chlorine - 2024 ERG Table 3
This is just an FYI to my Cl2 clients. Although the changes are NOT significant (0.1 - 0.3 miles), they are indeed changes to the Downwind Protective Action Distances. If you have used the 2020 ERG Distances in your Pre-Plans, which you or I did for your Emergency Response Plan (ERP), it may be beneficial to update them. REDUCED distances are highlighted Changes to Anhydrous Ammonia - 2024 ERG Table 3
This is just an FYI to my NH3 clients. Although the changes are NOT significant (0.1 - 0.2 miles), they are indeed changes to the Downwind Protective Action Distances. If you have used the 2020 ERG Distances in your Pre-Plans that you or I did for your Emergency Response Plan (ERP), it may be beneficial to update these pre-plans/ERP. REDUCED distances are highlighted 2024 ERG - CONSIDERATIONS FOR LITHIUM BATTERY AND ELECTRIC VEHICLE (EV) FIRES FIRE CONTROL
One of the many changes to the 2024 ERG, includes considerations for lithium battery and electric vehicle (EV) fires fire control. NOTE: the print editions are NOT yet available, but we can download the app (CLICK HERE) Water spray cools batteries and helps suppress and slow the release of toxic gases but does not stop the chemical reaction (thermal runaway). Other extinguishing agents (CO2, dry chemical, etc.) can trap heat instead of removing it and could result in false (lower temperature) readings. During an electric vehicle (EV) fire, consult the manufacturer's specific emergency response guide for help with identifying high voltage and medium voltage cabling. DO NOT CUT THESE CABLES. EPA RMP citations @ refrigerated distribution center and warehouse (NH3 & $161K)
The Respondent formerly operated an ammonia refrigeration process at a distribution center and warehouse, which maintained a maximum inventory of the regulated toxic substance anhydrous ammonia at the Facility, which exceeds the threshold quantity of 10,000 pounds of anhydrous ammonia as set forth in Table 1 at 40 C.F.R. § 68.130 and, therefore, has had a regulated substance present in more than a threshold quantity as determined under § 68.115, since at least 1999. At the Facility, the respondent operated a process, as defined in 40 C.F.R. § 68.3, that includes the use, storage, handling, and on-site movement of anhydrous ammonia, a regulated substance. The Covered Process at the Facility consists of seven compressors, three storage vessels, one high-pressure storage vessel, three condensers, 27 ammonia detection sensors, piping, and 100 evaporators (Covered Process). The Facility is subject to Program 3 because the Covered Process does not meet the Program 1 eligibility requirements at 40 C.F.R. § 68.10(g), and it is subject to the OSHA process safety management standard, 29 C.F.R. § 1910.119, in accordance with 40 C.F.R. § 68.10(i). On September 16, 2021, EPA conducted an announced inspection of the Facility. Prior to and during the September 2021 inspection, one business owned and the respondent operated the ammonia refrigeration system at the Facility. After the September 2021 inspection, the owner took over operations. During the September 2021 inspection, EPA inspectors reviewed documents relating to the RMP that the operator provided (RMP Documents). The RMP Documents included aspects of the Facility’s RMP involving the management system, process safety information, process hazard analysis, operating procedures, training, mechanical integrity, management of change, pre-startup safety review, compliance audits, hot work permits, employee participation, and contractors. Safety Cans... did you know?
Are "safety cans" created equally? Nope, and which UL standard they meet will dictate how much "safety they provide." OSHA's 1910.106 defines a "safety can" as
NFPA has a slightly different definition: The critical role a Hydrostatic RVs can play
A Y-shaped strainer (filter) in a three-inch pipe ruptured. The failure occurred after pressure cycles induced by thermal expansion. The released isobutylene resulted in a gas cloud explosion and the company's bankruptcy. Aspects:
"Over-Fill" requirements for Flammable Liquid Storage Tanks
Have you ever walked up to a atmopsheric storage tank and seen the paint bubbling and the hazard signs/placards faded/peeling off? Look up and you will most likely see the atmopsheric vent line on that side of the tank. What are these indicators of? The tank being over filled, which is a serious event and is certainly a Loss of Primary Containment (LOPC) event. But these days, these events should be a thing of the past, as the IFC and most state Fire Codes now require these flammable liquid Storage Tanks to have "Overfill" safety systems. (emphasis and revised structure by me) DOT tank vehicles and tank cars are NOT allowed to be used as flammable liquid storage tanks
Although it is done often, most state Fire Codes PROHIBIT the use of DOT tank vehicles and tank cars as "Flammable Liquid Storage Tanks." We call this "dropping trailers," and my 2014 Article "Dropping Trailers of Flammable Liquids" got quite the debate going. But trust me, there are sound engineering reasons why we can not and should not use DOT shipping containers as "flammable liquid" storage tanks. In this article, I provide those sound engineering reasons. Hint: Materials of Construction! NOTE: this unsafe practice can also have an impact on PSM/RMP coverage! Here is the OH Fire Code language (mimics the IFC) (emphasis by me) |
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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