"needs to make immediate improvements before tragedy strikes."

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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