CSB to OSHA: Extend PSM standard to onshore oil and gas drilling


Photo: Chemical Safety Board

Washington — Onshore oil and gas wells need appropriate well planning and control measures in place to “mitigate the potential for the ignition of flammable material,” the Chemical Safety Board says.

The recommendation is one of many in the board’s recently released final report on a January 2020 fire at the Wendland oil well in Texas’ Burleson County.

Three workers died and another suffered serious injuries after an ignition of hydrocarbons triggered a flash fire. Investigators found that the well operator and its contractors failed to enact thorough planning and control measures, leading to the release of the hydrocarbons.

CSB says insufficient industry guidance on well control for wells in an underpressured reservoir also contributed to the incident.

The agency renews its call on OSHA to either extend its standard on process safety management to the drilling of onshore oil and gas wells, customize it to oil and gas drilling operations, or create a new standard.

Addressing the report during a Jan. 25 CSB public business meeting, investigator-in-charge Harold Griffin said OSHA “has historically exempted” onshore oil and gas drilling from its standards on PSM and lockout/tagout (1910.147) despite it being a high-risk industry.

Griffin added: “As a result, there are minimal regulations that govern onshore oil and gas drilling and servicing operations despite prior attempts to promulgate special rules for this industry.”

CSB also recommends that companies with onshore oil and gas operations incorporate ignition source risk assessments in organizational policies while following industry regulations on the placement of ignition sources.

“As the U.S. continues to expand domestic energy production, both industry and the federal government must ensure that onshore oil and gas operations are conducted safely and under proper oversight,” CSB Chair Steve Owens said in a press release. “Three workers died because adequate steps were not taken to prevent this blowout and the fire that resulted.”

McCraren Compliance offers a full range of safety and health training and consulting services. Plus we can help you incorporate well-being into your traditional systems in order to support the Total Worker Health of your workforce.

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Original article published by Safety+Health an NSC publication

Safety board calls for an OSHA standard on liquid nitrogen

Lack of warning signs for the presence of liquid nitrogen and an asphyxiation hazard at the entrance to the freezer room from the loading dock (left) and clean room (right). (Credit: CSB and Messer)

Washington — Chemical facilities that handle hazardous gases or cryogenic asphyxiants such as liquid nitrogen should maintain atmospheric monitoring and alarm systems and educate workers on hazards.

The recommendations are part of a recently released final report from the Chemical Safety Board on a fatal January 2021 liquid nitrogen release at the Foundation Food Group Inc. poultry processing plant in Gainesville, GA.

Six workers died and four others sustained serious injuries after a freezer malfunctioned and released colorless, odorless liquid nitrogen into the air, displacing the oxygen in the room.

Investigators found that multiple workers who entered the freezer room after their shift started to check on co-workers had never received training on the fatal effects of nitrogen exposure. The facility also lacked air monitoring and alarm devices that might have cautioned workers against entering the room.

“Workers were not aware of the deadly consequences of a liquid nitrogen release – ultimately, trying to save their colleagues led to them sacrificing their own lives,” CSB investigator-in-charge Drew Sahli said in a press release. “This is a known hazard, and better training and communication could have prevented such a tragedy.”

The report offers multiple safety lessons, including:

  • Processes and equipment that involve hazardous materials should be designed robustly enough that the failure of a single component cannot result in a catastrophic incident.
  • Designating competent and resourced staff with responsibility over specific safety programs is key to ensuring effective process safety. Management must be knowledgeable and involved in each of these safety programs to provide effective oversight.
  • Organizations must be cognizant of the hazards posed by the chemicals they handle and should implement effective process safety management systems to control process safety risks.

Further, CSB calls on OSHA to issue a national standard addressing hazards related to the storage, use, and/or handling of liquid nitrogen and other cryogenic asphyxiants. CSB also recommends OSHA include liquid nitrogen in its Regional Emphasis Programs for poultry processing and food manufacturing.

“CSB’s recommendations are important for preventing incidents involving liquid nitrogen and lessening their severity if they do occur,” CSB Chair Steve Owens said in the release. “The hazards of liquid nitrogen must be clearly communicated to workers, and the safety management systems for operations that use liquid nitrogen must be improved.”

McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

Original article published by Safety+Health an NSC publication

‘Incredibly destructive’: CSB publishes report on fatal dust explosion


Photo: Chemical Safety Board

Washington — Hazards related to combustible dust “must be controlled beyond the existing regulatory requirements,” says the Chemical Safety Board, which renewed its call for OSHA to begin rulemaking on a general industry standard.

CSB addresses the issue in a recently released final report on a fatal May 2017 explosion and fire at the Didion Milling dry corn mill in Cambria, WI. Five workers were killed and 14 were injured.

CSB investigators found that the company neglected to develop and implement a written program on combustible grain dust, and failed to install venting or suppression on a dust filter collector to prevent an explosion. However, the agency notes that Didion Milling wasn’t required to enact various safety management systems because OSHA lacks an overarching general industry standard for combustible dust.

CSB recommends that an OSHA standard address hazard recognition, dust hazard analysis, incident investigation, engineering controls, operating procedures, process safety information and training.

Other recommendations:

  • Employers should ensure pneumatic transport and dust collection ductwork is designed to maintain a minimum transport velocity.
  • Engineering controls such as detection, suppression, isolation, venting and pressure containment should be used during the design of dust safety systems.
  • Employers should review fire and building codes to determine the type of construction and evaluate additional requirements based on the materials being handled.
  • Employers should ensure the standards applied are applicable and appropriate to hazards inside the facility.
  • Employers should consider abnormal and upset conditions when assessing personal protective equipment.

“Combustible dust explosions and fires can be deadly and incredibly destructive,” CSB Chair Steve Owens said in a press release. “The terrible tragedy at Didion was made even worse due to the lack of important safeguards in the design of the mill equipment and the lack of engineering controls at the facility that could have reduced the potential for serious fires and explosions.”

McCraren Compliance offers a full range of safety and health training and consulting services. Plus we can help you incorporate well-being into your traditional systems in order to support the Total Worker Health of your workforce.

Call 888-758-4757, email info@mccrarencompliance.com or visit our website www.mccrarencompliance.com

Original article published by Safety+Health an NSC publication

Investigation of chemical release leads to recommendations on written procedures

Original article published by Safety+Health
Photo: Chemical Safety Board

Washington — Facilities that produce or handle hazardous chemicals should prepare written procedures and establish policies for evaluating simultaneous operations to ensure “robust safe work practices,” the Chemical Safety Board says.

The recommendations are among 10 outlined in CSB’s final report on a deadly chemical release in November 2020 at the Wacker Polysilicon North American facility in Charleston, TN.

One worker died and two others suffered serious injuries when they attempted to escape a cloud of toxic hydrogen chloride gas. Unable to see their surroundings, the workers fell 70 feet while trying to climb down a tower near the platform on which they were working.

CSB says seven contractors from two firms were working on separate projects on the platform.

The agency found that Wacker’s lack of written procedures and lack of control of hazardous energy contributed to the event, as did the lack of a simultaneous operations program and the lack of regulatory and published industry guidance on SIMOPs.

The report highlights four safety lessons:

  • Written procedures are a “critical tool for ensuring safe operations and maintenance activities” and “consolidate information required to execute a given task into easy-to-understand step-by-step instructions, with specific reference to safety precautions and critical actions.”
  • The control of hazardous energy “should be considered whenever equipment containing hazardous energy is repaired, adjusted, serviced and maintained, not only in situations in which equipment is intentionally opened.” Before work begins on equipment containing hazardous energy, “a risk assessment should always be performed to evaluate the need for energy isolation or other protective measures.”
  • “Owners and operators should always consider how simultaneous operations, or SIMOPs, could impact a given operation, whether by influencing a hazard or affecting the risk of the operation.” SIMOPs “should be identified and controlled via a hazard assessment” before an operation or task begins. A well-established system “must be able to document the specific task to be executed, readily coordinate the issued permits and identify scenarios of potential interaction between permitted work groups.”
  • “Owners and operators should prioritize the implementation” of process hazard analysis recommendations and employee input “to control hazards that have been identified by those closest and most familiar with facilities and operations.”

Further, CSB recommends that OSHA:

  • Create a standard or modify existing standards to require employers to ensure the coordination of SIMOPs involving multiple work groups, including contractors.
  • Develop a safety product – not limited to confined space or construction – that provides guidance on the coordination of SIMOPs involving multiple work groups.

McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

CSB Issues New Safety Alert Focused on the Potential Hazards of Emergency Discharges from Pressure Release Valves

Original article published by CSB
safety alert

Photo property of CSB

Washington, D.C. March 6, 2023 – Today, the U.S. Chemical Safety and Hazard Investigation Board (CSB) issued a new Safety Alert titled “Hazards Posed by Discharges from Emergency Pressure-Relief Systems.” The CSB’s alert highlights hazards identified with emergency pressure-relief systems from four CSB investigations.  The alert advises facilities that while a discharge from emergency pressure-relief systems can help protect equipment from unexpected and undesired high-pressure events, it can also seriously harm or fatally injure workers and cause extensive damage to a facility if the discharge is not made to a safe location.

CSB Chairperson Steve Owens said, “All four of the incidents highlighted in the CSB’s safety alert underscore the importance of thoroughly evaluating emergency pressure-relief systems to ensure they discharge to a safe location where they will not harm people.”

The four incidents highlighted in the CSB’s safety alert resulted in 19 deaths and 207 injuries. They include:

  • On May 19, 2018, an ethylene release ignited, injuring 23 workers at the Kuraray America, Inc. ethylene and vinyl alcohol copolymer plant in Pasadena, Texas. The CSB’s animation of this event shows how this incident occurred during the startup of a chemical reactor system following a turnaround. High-pressure conditions developed inside the reactor and activated the reactor’s emergency pressure relief system, discharging flammable ethylene vapor horizontally into the ambient air in an area where a number of contractors were working.
  • On November 15, 2014, approximately 24,000 pounds of highly toxic methyl mercaptan were released from an insecticide production unit at the E.I. du Pont de Nemours and Company (DuPont) chemical manufacturing facility in La Porte, Texas. The release fatally injured three operators and a shift supervisor inside a manufacturing building. During the early phases of the investigation, CSB investigators identified a number of worker safety issues—separate from the release scenario— including that several emergency pressure-relief systems at the facility were designed to discharge hazardous materials in a way that posed a risk to workers and the public.
  • On May 4, 2009, highly flammable vapor released from a waste recycling process, ignited, and violently exploded at Veolia ES Technical Solutions, LLC, in West Carrollton, Ohio. The incident injured four employees, two seriously.  Following the initial explosion, multiple other explosions occurred that t significantly damaged every structure on the site. Residences and businesses in the surrounding community also sustained considerable damage. The CSB concluded that uncontrolled venting from emergency pressure-relief valves to the atmosphere allowed tetrahydrofuran (THF) vapors to accumulate to explosive concentrations outside process equipment, and the vapors subsequently found an ignition source.

Chemical Safety Board calls on OSHA to provide guidance on process hazard analysis

Original article published by Safety+Health

Photo: Chemical Safety Board

Washington — OSHA should develop guidance on the process hazard analysis element of its standard on process safety management of highly hazardous chemicals (1910.119), the Chemical Safety Board recommends in a final report on an April 2018 explosion and fire at a Wisconsin refinery.

CSB makes 16 recommendations in the report that are directed at OSHA, the Environmental Protection Agency, the American Petroleum Institute, two energy companies and the Husky Energy refinery in Superior.

The explosion occurred in the refinery’s fluid catalytic cracking unit while workers were on a break during a scheduled maintenance shutdown. Debris from the ensuing blast flew about 200 feet and punctured an aboveground storage tank containing asphalt. This caused more than 15,000 barrels of hot asphalt to spill into the refinery. The asphalt ignited about two hours later, resulting in a large fire.

OSHA’s PSM standard requires employers to have safety programs that identify, evaluate and control hazardous chemicals. CSB calls for the recommended agency guidance to place particular focus on safe operating procedures during transient operations – including startup, shutdown, standby and emergency – in facilities with processes covered by the PSM standard.

“Transient operations can pose unique hazards that may not occur during normal process operations,” the report states.

In addition to the recommendations, CSB outlines multiple lessons aimed at preventing incidents and “driving chemical safety change” within the industry. They include:

• Ensure operators understand how air or oxygen may enter during transient operations involving flammable materials, and how oxygen should be purged from the system to prevent the formation of flammable mixtures.

• Understand the process and reasoning behind venting and purging procedures and the impact these carry on process units.

• Perform process hazard analyses on critical operating procedures to spotlight hazards that occur during transient operations.

• Include in operator training hands-on opportunities for “rare but critical tasks,” including shutting down a process unit safely for a turnaround.

“These safety issues seek to address incident causes,” CSB member Sylvia Johnson said in a press release. “We call on refineries, trade groups, and regulators to examine our final report and apply the key lessons to help ensure safe operations at facilities throughout the country and to develop and adopt effective emergency response practices.”

McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

Chemical Safety Board to chemical facilities: Remember cold-weather best practices

Original article published by Safety+Health


Photo: CSB

Washington — Alarmed by a recent surge of events involving the incidental release of chemicals during cold weather, the Chemical Safety Board is reminding facility operators of process safety management best practices for wintertime operations.

Freezing and expansion of water can crack or break pipes, damage equipment, or lead to instrumentation failure. Additionally, cold temperatures can trigger the formation of a hydrate, a chemical combination of water and a compound that may expand or block process piping.

CSB recommendations for winterization include:

  • Effectively identify and address the risk of freeze-related hazards to piping and process equipment through process hazard analyses, management of change evaluations, pre-startup safety reviews and operating procedures.
  • Create and implement a winterization checklist to ensure plant and process systems are ready for cold weather.
  • Establish a formal, written freeze protection program.
  • Survey piping systems for dead-legs (sections that have no flow) and ensure they’re properly isolated, removed or winterized.
  • Systematically review process units, including infrequently used piping and equipment, to identify and mitigate freezing hazards.

CSB data shows that 36 incidents related to the agency’s accidental release reporting rule were recorded during the first three months of fiscal year 2023, including eight during a Christmas holiday weekend that saw record-low temperatures across much of the nation.

The agency notes that 30 combined reportable events – incidental chemical releases resulting in a fatality, a serious injury and/or significant property damage – were observed during the first quarter of FY 2021 and FY 2022.

“Companies need to heighten their focus on safe operations and recognize that taking important precautionary actions, like winterization, can help prevent major chemical accidents,” CSB Chair Steve Owens said in a press release.

McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

OSHA, MSHA receive smaller-than-expected budget increases for FY 2023

Original article published by Safety+Health

Washington — OSHA and the Mine Safety and Health Administration will receive modest budget increases for fiscal year 2023 – far less than the amounts initially proposed by Congress and the White House.

Under the FY 2023 federal appropriations bill signed into law by President Joe Biden on Dec. 29, OSHA is set to receive around $632.3 million for FY 2023 (which ends Sept. 30). That’s an increase of about $20 million, or 3.3%, from FY 2022. The Senate proposed $679.8 million for the agency in its Labor, Health and Human Services, Education, and Related Agencies appropriations bill, released in July.

The House announced in June that it had approved $712 million for OSHA. The Biden administration sought $701 million in its budget request, issued in March.

Federal enforcement and state programs will get the bulk of OSHA’s modest budget increase. Those line items are set to go up $7 million each, to $243 million and $120 million, respectively.

MSHA is getting a $4 million (1%) budget increase, to approximately $387.8 million, in FY 2023. The Senate proposed $409.6 million, the House budgeted $403.8 million and the administration sought $423.5 million for the agency. Enforcement will get nearly $1.3 million of that $4 million increase, to almost $265.8 million.

NIOSH is set to receive $362.8 million – an $11 million (3.1%) increase from FY 2022. That’s closer to the congressional bills (a proposed $367.3 million from the Senate and $363.3 million from the House). The administration requested a $6.5 million decrease in NIOSH’s budget, to $345.3 million.

The Chemical Safety Board has a budget of $14.4 million for FY 2023 (a 7.5% increase) – exactly what the Senate and House proposed in their initial bills. The administration requested $14 million for the agency, or a $600,000 increase from FY 2022.

McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

‘Multiple perspectives’: CSB releases first ‘learning review’ on combustible dust












Photo: U.S. Chemical Safety Board

First published by Safety+Health an NSC publication.

Washington — Managing and controlling combustible dust should be considered a unique hazard – not simply “tidying up the place,” the Chemical Safety Board says in a recently released learning review document that includes input from workers and industry stakeholders.

Prepared by Dynamic Inquiry LLC on behalf of the agency, the 47-page document compiles feedback solicited by CSB in a Call to Action – issued in October 2018 – stemming from a May 2017 explosion and fire that killed five workers and injured 14 others at the Didion Milling Co. facility in Cambria, WI. The agency sought comments on the management, control and understanding of combustible dust.

“This learning review represents a new method for the CSB to examine an incident,” CSB Chair and CEO Katherine Lemos said in a Sept. 10 press release. “The outcome of this specific review provides an opportunity for dust hazards to be examined from multiple perspectives, which may allow for a greater understanding of preexisting assumptions and scenarios.”

CSB said it found that more efficient sharing of information between companies, industries and regulators – facilitated openly and without fear of punishment and reprisal – was the stakeholders’ most sought-after goal. Numerous respondents to the Call to Action indicated that a possible normalization of the risk contributed to the ongoing difficulty of keeping facilities dust-free.

Additionally, the document renews CSB’s long-standing call for OSHA to issue a standard on combustible dust. CSB identified 386 combustible dust incidents from 1980 to 2017 that resulted in 178 fatalities and more than 1,000 injuries.

Other recommendations for controlling and mitigating combustible dust hazards include:

  • Develop standards to certify dust collection system manufacturers, installation and training.
  • Advance psychological safety within organizations to improve the willingness of personnel to provide information and ask questions.
  • Explore ways to promote effective communication within and between facilities, including eliminating language barriers. “Even the words used to describe combustible dust can introduce vulnerabilities to the system,” the report states.
  • Acknowledge that training doesn’t always ensure learning. Create experiential and collaborative learning methods within facilities.
  • Establish an online forum and/or a “lessons learned center,” which allows the community to explore combustible dust issues and share feedback.

“CSB hopes that this product provides further insight and understanding of combustible dust hazards,” Lemos said. “Our goal is to continue to examine incidents from multiple perspectives to better enhance prevention and continually drive chemical safety.”

McCraren Compliance assists employers in protecting their workers, starting with a comprehensive Work-site Analysis, Hazard Prevention, Controls, and Safety & Health Training.

Preparing chemical facilities for extreme weather events: CSB releases safety alert, video

Photo: Chemical Safety Board

Washington — The Chemical Safety Board has published a safety alert and video intended to help hazardous chemical facilities prepare for hurricanes and other extreme weather events.

Announced in a June 23 press release, the safety alert and five-minute video include highlights from a Center for Chemical Process Safety guidance document. Assessment of and Planning for Natural Hazards, published in October, was developed after CSB’s investigation into an August 2017 incident at an Arkema Inc. chemical plant in Crosby, TX.

After flooding from Hurricane Harvey caused an evacuation of the facility, organic peroxide products stored inside a formerly refrigerated trailer decomposed and caught fire, releasing dangerous fumes and smoke into the air. Officials initially chose to keep a nearby highway open and, as a result, 21 people needed medical attention for exposure to hazardous fumes. More than 200 residents living nearby were later evacuated and could not return home for a week.

CSB found “a significant lack of industry guidance on planning for flooding or other severe weather events” despite an increase in flooding throughout the United States in recent years.

“Some experts predict this trend will continue,” CSB Chair and CEO Katherine Lemos says in the video. “The incident at Arkema is not an anomaly.

“When analyzing safety hazards at a facility, companies are not specifically required to consider the risks of extreme weather. For this reason, I’m concerned that other companies may not be aware of the potential for flooding to create process safety hazards.”