Chlorine is used in our
industry as one method to remove impurities in aluminium. The Aluminium Plant
Safety Blog has posted incidents involving the hazard of the unexpected release
of chlorine gas in our plants. Here is a recent story:
Workers risked
exposure to dangerous chlorine gas while forging blocks of metal material at an
aluminum foundry because their employer did not train them on how to handle and
store the gas, U.S. Department of Labor Occupational Safety and Health
Administration inspectors found. Improperly used, chlorine gas can cause severe
respiratory damage.
Unsafe use of the
gas was discovered by OSHA at an aluminium foundry in the Fall 2014 after a
complaint prompted an inspection. Investigators found employees endangered by
permit-required confined space
hazards while working in foundry
furnaces. A confined space is one large enough for workers to enter and perform
certain jobs, such as a holding tank, but it has limited or restricted means
for entry or exit and is not designed for continuous occupancy.
As a result, OSHA
issued over 30 serious health and safety citations with proposed penalties of €
150,000. Inspectors determined the aluminium foundry failed to train workers on hazardous chemicals used at the foundry; store oxygen and
fuel-gas cylinders properly, and protect workers from dangerous machine parts.
The agency also found forklifts with defects in use.
"With more
than 30 violations, it's clear that the safety and health of its workers are
not priorities at the aluminium foundry. Failing to provide training, safety
equipment is unacceptable," said the OSHA's area director in. "The
foundry needs to make immediate improvements before tragedy strikes."
The aluminium
foundry also failed to conduct audiometric
testing; ensure hearing protection was worn; and to train employees on noise
hazards. Noise-related hearing loss is one of the most prevalent occupational
health concerns in the U.S., with an estimated 30 million people occupationally
exposed to noise each year. This exposure can cause permanent hearing loss that
neither surgery nor a hearing aid can correct.
A serious
violation occurs when there is substantial probability that death or serious
physical harm could result from a hazard about which the employer knew or
should have known.
The
aluminium foundry has contested the citations and penalties and the case may go
before an independent Occupational Safety and Health Review Commission.
The
aluminium foundry was cited for the following violations:
·
Serious
Violations (occurs when there is
substantial probability that death or serious physical harm could result from a
hazard about which the employer knew or should have known).
o
Employee(s)
were exposed to the release of chlorine compounds to the atmosphere that can
lead to injury or death to persons working at the facility)
o
Employee(s)
working in the chlorine process did not have access to the following process
safety information; metal tubing used to connect the ton cylinder to the
process piping, lead washers, ton cylinders, Jamesbury valves, chlorine
spreader bar used to lift ton cylinders, chlorine hard metal piping,
evaporators, isolation valves (yoke), chlorine storage racks, pipe thread tape
used in the chlorine process, evaporator pressure relief valves, inline rupture
discs for the 2 evaporators, chlorine flexible metal piping
o
At
the facility, the over-pressurization of the liquid or gas chlorine pipe lines
and the outside chlorine gas sensors share the same alarm system. This does not
comply with recognized and generally accepted good engineering practices. In
the event of an over-pressurization of a liquid or gas pipe line, the
activation of the alarm system would be the same as chlorine gas being detected
by the chlorine gas sensors located in the evaporator room and outside at the
chlorine cylinder connecting area. Employees responding to an alarm would not
be able to distinguish between different scenarios until they arrived at the
chlorine processing area.
o
The
employer did not perform an initial process hazard analysis.for the chlorine
process.
o
At
the facility, the employer failed to provide to employees connecting chlorine
cylinders to the process written operating procedures providing clear
instructions addressing the following elements: 1) temporary operations 2)
emergency operations 3) start-up following an emergency shut down 4) operating
limits 5) consequences of deviations 6) steps required to correct deviations
o
At
the facility the employer did not develop written operating procedures that
provided clear instructions to safely operate the evaporators, for all chlorine
operators.
o
At
the facility the employer did not develop written operating procedures that
provided clear instructions to safely change out chlorine tubes that are
inserted into the molten metal at the furnaces.
o
At
the establishment the employer had not provided process safety management
training to operators and maintenance personnel performing tasks in the
chlorine process.
o
At
the establishment the employer did not obtain the safety and health programs of
the contactor that delivers chlorine ton cylinders and the contractor that
maintains the integrity of the chlorine process.
o
The
employer did not develop and implement a written mechanical integrity procedure
that addressed inspecting pressure vessels and piping for corrosion, minimum
wall thickness, etc.
o
The
employer did not develop a written integrity procedures for evaluating the
metallic flexible tubing that are changed out every 6 months to determine if
the replacement policy was adequate.
o
The
employer did not develop and implement a written procedure for evaluating
valves in the chlorine process.
o
The
employer did not develop and implement a procedure for evaluating ton cylinders
received from a contractor for the chlorine process.
o
At
the facility the Chlorine piping along the north and east wall of the Chlorine
process had not received non-destructive testing to determine if the
manufacturer's minimum wall thickness had been exceeded.
o
At
the facility the Chlorine piping from the evaporator room to the furnaces had
not received nondestructive testing to determine if the manufacturer's minimum
wall thickness had been exceeded.
o
At
the facility the evaporators in the Chlorine process had not received
mechanical integrity inspections for corrosion.
o
At
the facility pressure vessels such as the liquid expansion vessel had not
received a mechanical integrity inspection to determine if there were any
corrosion damage and to establish a corrosion rate for the vessel.
o
At
the establishment a written emergency action plan did not address procedures to
be followed by employee(s) required to remain at their position to plug any of
the furnaces in the production department before they can evacuate, during a
chlorine gas leak
o
At
the facility a written emergency response program had not been developed nor
implemented to inform employees responding to Chlorine gas I liquid leaks in
the Chlorine process of the health hazards associated with Chlorine.
o
The
employer did not establish a program consisting of an energy control procedure,
employee training and periodic inspections to ensure that before any employee
performed any servicing or maintenance on a machine or equipment where the
unexpected energizing, startup or release of stored energy could occur and
cause injury, the machine or equipment shall be isolated from the energy source
and rendered inoperative.
o
At
the establishment the employer had not developed and implemented a written
energy control program designed to ensure employees were not exposed to the unexpected
energization of the equipment when performing maintenance and preventative
maintenance on the furnaces, rotaries, evaporators, and etc.
o
An
educational program was not provided for all employees to familiarize them with
the general principles of fire extinguisher use and the hazards involved with
incipient stage fire fighting:
o
Employee(s)
utilizing fire extinguishers to address small incipient stage fires at the
establishment were exposed to fire hazards due to no fire extinguisher training
being performed.
o
Employee(s)
operating forklifts at the establishment were not evaluated prior to operating
an industrial truck to determine competency, thus exposing employees walking
around the facility to struck-by hazards.
o
Powered
industrial truck(s) found to be in need of repair, defective, or in any way
unsafe had riot been taken out of service until restored to safe operating
condition(s):
o
Employee(s)
operating industrial fork trucks at the establishment with defects were
exposing employee(s) walking around to struck-by hazards. The following industrial
fork trucks had the following conditions: (a) no functioning parking brake or
horn, (b) no functioning turn signal lights, (c) had no functioning parking
brake, horn, and leaking hydraulic fluid from the left side mast cylinder (d) no functioning parking brake or horn.
o
Industrial
trucks were not examined, at least daily or before each shift if used on a
round-the clock basis, before being placed into service.
o
Powered
industrial truck(s) found to be in need of repair, defective, or in any way
unsafe had riot been taken out of service until restored to safe operating
conditions.
o
Employees
were exposed to excessive noise levels. Audiometric testing had not been
provided. Full shift noise dosimetry indicated Time Weighted Average noise
exposures ranging from 86.9 dB to 93.0 dB for employees working on the Tap Crew
as a Rotary Furnace Assistant and in Shipping/Receiving. Five of the six
employees sampled were found to be exposed to noise above 85 dB, the action level
o
Employees
were exposed to excessive noise levels. Employees were unaware that hearing
protection was required and the use of hearing protection was not enforced.
Full shift noise dosimetry indicated Time Weighted Average noise exposures
ranging from 86.9 dB to 93.0 dB for employees working on the Tap Crew, as a
Rotary Furnace Assistant and in Shipping/Receiving. Five of the six employees
sampled were found to be exposed to noise above 85 dB, the action level.
o
The
employer did not train each employee who is exposed to noise at or above an
8-hour time-weighted average of 85 decibels in accordance with the requirements
of 29 CFR 1910.95(k). The employer did not institute a training program and
ensure employee participation in the program:
o
Employees
were exposed to excessive noise levels and had not been provided with the
required hearing conservation training. Full shift noise dosimetry indicated
Time Weighted Average noise exposures ranging from 86.9 dB to 93.0 dB for
employees working on the Tap Crew, as a Rotary Furnace Assistant and in
Shipping/Receiving. Five of the six employees sampled were found to be exposed
to noise above 85 dB, the action level.
o
The
in-plant handling, storage, and utilization of all compressed gases in
cylinders, portable tanks, rail tank cars, or motor vehicle cargo tanks were
not in accordance with Compressed Gas Association Pamphlet P-1-1965, which is
incorporated by reference as specified in CFR 1910.6:
o
Employees
were exposed to injury from fire and explosion or a projectile hazard.
Compressed gas cylinders, that were not in use, were not secured to prevent
damage in accordance as required by Compressed Gas Association Pamphlet
P-1-1965.
o
Employees
whose work activities require entry into the chlorine evaporator room, such as
maintenance employees and employees changing chlorine tanks, are exposed to
injury from being trapped in the evaporator room by a chlorine release. An
emergency escape respirator was not provided in the evaporator room to escape a
chlorine release.
o
Employees
were exposed to injury from the hazards associated with confined space entry.
An evaluation of the workplace had not been conducted to locate and determine
the hazards associated with the confined spaces present. Furnaces and rotary
furnaces meeting the definition of permit required confined spaces were not
identified and treated as confined spaces. There were 3 furnaces and 3 rotary
furnaces in the production area
o
Employees
were exposed to injury from the hazards associated with confined space entry.
Signs had not been posted to make employees aware of the location and dangers
associated with confined spaces. Furnaces and rotary furnaces meeting the
definition of permit required confined spaces were not provided with warning
signs. There were 3 furnaces and 3 rotary furnaces in the production area.
o
Employees
were exposed to injury from the hazards associated with confined space entry. A
written confined space entry program that addressed the hazards of entering
furnaces and rotary furnaces, which meet the definition of permit required
confined spaces, had not been developed or implemented. There were 3 furnaces
and 3 rotary furnaces in the production area that were periodically entered by
employees.
o
Employees
were exposed to injury from the hazards associated with confined space entry.
Air sampling to ensure safe entry conditions and to evaluate atmospheric
hazards was not conducted prior to entering furnaces and rotary furnaces, which
meet the definition of permit required confined spaces. There were 3 furnaces
and 3 rotary furnaces in the production area that were periodically entered by
employees.
o
Employees
were exposed to injury from the hazards associated with confined space entry.
The use of entry permits was not developed or implemented to ensure that hazards
associated with furnace entry were recognized, evaluated and controlled prior
to entering furnaces and rotary furnaces. There were 3 furnaces and 3 rotary
furnaces in the production area that were periodically entered by employees.
o
Employees
were exposed to injury from the hazards associated with confined space entry.
Employees entering confined spaces had not been trained to recognize, evaluate
and control the hazards associated with furnace and rotary furnace entry. There
were 3 furnaces and 3 rotary furnaces in the production area that were
periodically entered by employees.
o
Employees
were exposed to injury from fire and explosion or a projectile hazard. The
valve cap was not installed on the small compressed gas cylinder of oxygen in
storage to prevent damage to the valve.
o
Employees
were exposed to injury from fire and explosion. Two compressed gas cylinders of
acetylene were stored with four compressed gas cylinders of oxygen in the
cylinder storage area located in the southeast comer of the production area.
o
Employees
were exposed to injury from exposure to hazardous chemicals. Two large tanks,
possibly fuel tanks, were not labeled with the identity of the contents or a
hazard warning.
o
Employees
were exposed to injury from exposure to hazardous chemicals. Employees
providing maintenance on components of the chlorine system, employees changing
the chlorine tanks, employees responding to chlorine leaks, and employees in
the facility that could be exposed to chlorine in the event of a leak were not
provided training on the hazards associated with exposure to chlorine.
This aluminium foundry is contesting the citations. Nevertheless,
each and every issue cited above can lead to an incident involving an injury
and/or fatality.
The company was cited repeatedly for not following the guidelines
outlined in the Compressed Gas Association Pamphlet P-1-1965. That document can
be found here.
So the question is what should you do after reading this blog post?
a)
Nothing
b)
Print it out and give it to your plant’s EHS manager?
c)
Print it out and give it to your plant manager?
d)
Both B & C
The answer is anything except “A”. This is an ideal opportunity to
take by learning from what another company was cited for. So, please print this
out and review it. If your company can identify any of the hazards listed above
in your facility, please remedy immediately.
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