EH&S News
Environmental Health and Safety
University of Massachusetts at Amherst
Editor: Robert DiCarlo Fall 1999 Vol. 5 No. 3
Inside This Issue
Unannounced RAD Inspection
Notice to Researchers who use Arochlor Compounds
Hydrogen Fluoride Shelf Life Issue
Trenching and Shoring
Confined Spaces
Early this fall semester Mr. A. Savastano and Mr. R. Fairfull with the Massachusetts Radiation Control Program (MRCP) arrived unannounced to inspect the UMass licensed radiation protection program. The inspectors reviewed the program and records. They visited four authorized user labs and performed a routine survey.
They reviewed RAM use locations listed on our license at UMass Amherst, Cranberry Station, Gloucester Marine Station, Waltham Field Station, and The Conte Anadromous Fish Research Center.
The inspectors met with the Radiation Use Committee (RUC) and EH&S Director at a close-out meeting. Mr. Savastano indicated that they found no items of violations and further stated that we had a “model program”. The importance of wearing lab coats, gloves, eye protection was stressed. Dr. Sastry, RUC Chairperson commented in response to their request for questions; he gave credit to the EH&S staff for their hard work in maintaining the program.
EPA Region I has targeted Colleges and Universities for increased regulatory scrutiny. Interpretation of the existing regulations differ within EPA from region to region. Regulatory interpretation relative to the use and disposal of these compounds under the research exemption has changed.
Please contact Jim Field at (jmfield@admin.umass.edu)
or Jim Fox at
(jpfox@uhs.umass.edu)
or call EH&S at 5-2682
to discuss these changes.
We would like to inform you of a potential storage hazard which others in our industry have experienced, and which we are communicating to you to help ensure your continued safe use of the products you buy from Air Products and Chemicals.
There is a potential over-pressure hazard with the long term storage of carbon steel cylinders containing Anhydrous Hydrogen Fluoride (AHF). The AHF in the cylinder reacts very slowly with the iron in the steel to form iron fluoride and hydrogen. The hydrogen collects in the vapor space and builds pressure.
An HF lecture bottle (DOT 3E) that had been in storage for as long as 14 years was found to be at an estimated pressure of 2400 psig. While venting the contents of this cylinder to a scrubber, the vented gas was analyzed and found to be primarily hydrogen. The expected pressure based upon the AHF's vapor pressure should have been between 5 - 15 psig.
There have been a few reported cases worldwide of AHF cylinders failing after approximately 15-25 years of storage due to over-pressurization from hydrogen build-up.
If your facility has carbon steel cylinders containing AHF, you should not store these cylinders for extended periods of time without monitoring pressure and cylinder condition. Extreme caution should be taken during the handling of any AHF cylinders that have been stored for extended periods of time. As with any handling of HF, proper safety procedures should always be used and first aid supplies should be available in the event of personnel exposure.
You should also consider any potential impact on your operation of using the gas from any AHF cylinder that has been stored for extended periods of time since it may now contain hydrogen as well as the AHF.
This communication is consistent with the goals of Responsible Care and reinforces Air Products' leadership in communicating product stewardship and safety issues to our customers. We encourage you to communicate this information to any others in your location who may have access to the AHF cylinders you purchased.
If you have any questions, please contact the Product Stewardship Technical Information Center at 1-800-752-1597.
SAN FRANCISCO -- The Occupational Safety and Health Administration has issued
citations for willful and serious violations of federal safety and health standards against a
Guam construction company which allowed employees to work in a hazardous trench
without adequate protections to prevent cave-ins.
Following an inspection of the Fargo Pacific, Inc. work site at the Polaris Point Naval
Station, OSHA issued citations for two willful violations, which include penalties of
$112,000, and one serious violation, with penalties of $3,600.
The willful violations include failure to remove water from the excavation and the lack of
shoring to prevent cave-in. The serious violation is for failing to provide a competent
person to oversee employee safety in the excavation.
"Fargo Pacific was charged with willful violations because the company allowed employees to work in a trench as much as ten feet deep even after receiving a warning of the
hazards," explained Leonard Limtiaco, OSHA regional director of enforcement and
investigations. "The U.S. Navy inspected this same site two days before OSHA
investigators arrived and provided Fargo with written notice of the hazards associated
with allowing work in this excavation without cave-in protection for workers."
The OSHA inspection was a routine, scheduled inspection, begun February 3, 1999. OSHA has inspected Fargo Pacific nine times in the past three years. As a result of those
inspections the company has been cited for nine serious violations, five other than
serious violations and six unclassified violations.
OSHA issues a willful citation only in cases in which the employer knew that a condition
constituted a violation or was aware that a hazardous situation existed and made no
reasonable effort to correct it. OSHA issues a serious citation only when there is
substantial probability that death or serious physical harm could result, and the employer
either knew, or should have known, of the hazard.
The employer has 15 working days from the date of the notice to contest the citations
and proposed penalties before the Occupational Safety and Health Review Commission - a
government judicial agency separate from OSHA.
Most people who pass over the campus grounds day in and day out have no idea of the amount of behind the scenes work that keeps the University functioning. Let’s take a look at the Utilities Workers of the Physical Plant. These employees work in all sorts of less than desirable spaces to make sure that the buildings continue to have heat, hot water, and electricity.
A maze of underground tunnels exists below the feet of all of us who walk around campus. O.S.H.A. (Occupational Safety and Health Administration) has mandated a worker safety standard to help improve the safety of these spaces for workers all over the United States. These standards came about in an answer to preventable employee deaths and injuries from incidents that occurred in spaces similar to those that University employees enter each day.
The confined space safety standard describes a confined space as any space that: (1) is large enough for a person to enter and to do work, (2) has a limited access or egress point, and (3) is not made for continuous worker occupancy.
The federal Confined Space regulations deal with specific requirements before employees can enter and work in confined spaces. Some of these requirements include confined space evaluation, hazard assessment (e.g. air monitoring or lock-out/tag-out of specific hazards), adequate communications and employee monitoring, and the availability and use of rescue equipment.
The philosophy behind the safety standard is to have the confined space assessed before and during worker occupancy to ensure that the space is safe. The standard also is so that in the event that a confined space entrant or occupant is incapacitated, there are emergency reporting and rescue procedures in place.
The University has worked to develop a safety program and procedures that meet the standards set up through O.S.H.A. in regards to the need for confined space entries on campus. Included in this cooperative effort have been representatives from EH&S, the Physical Plant, Housing Services, and Auxiliary Services.
University employees are very conscious of their own safety. One of the ways to promote their safety in the use of the confined space policy is cooperation with the rescue services provided through the Amherst Fire Department.
Members of the Physical Plant Utilities Department have spent considerable time over the past several months working with members of the Amherst Fire Department in familiarizing them with the spaces around the campus.
Culminating this educational effort was a confined space rescue drill that was held on campus in late July. The scenario put into motion for the drill was that an occupant of a steam tunnel stopped communicating with the attendant of the confined space atop the entry point to the space.
This put into motion the emergency procedures in place to provide rescue services for anyone trapped or otherwise unable to exit a confined space. The confined space attendant, that person in place outside of the confined space to monitor the workers inside, has the toughest job of all. He must remain outside the area and not enter to help his co-workers.
This is because the reason for the workers becoming incapacitated is not known. By entering the space to “rescue” his or her co-workers, the attendant will probably become a victim himself. National statistics show that over 70% of all confined space fatalities are those people who attempted to make rescues of others inside the space.
If proper rescue equipment is in place, like a harness, lifeline, and retrieval system, the attendant can rescue a worker inside the confined space by retracting the lifeline and removing the injured occupant without ever entering the space.
During the drill, the occupant of the confined space did not have on any rescue retrieval equipment. This made the task of removal more difficult for the responding rescuers from the fire department. They had to set up a tripod, provide for their own safety through air monitoring and rescue retrieval systems, and then package the victim for removal from the confined space.
Prior to entering the confined space to initiate the rescue, those responding with the fire department needed to gather information from the attendant about what is going on in the confined space. This important information helps them to evaluate the hazards and promote a safe and efficient rescue operation.
One means for gathering this data is through the confined space entry permit. When a permit required confined space is entered the attendant must fill out a permit specific to that space. Information included on the permit are air monitoring readings, known hazards in the space, name of the entrant in the space, and any needed ventilation requirements. The permit also provides reminders to the workers on the need for rescue equipment to be on site and used as the space is entered and emergency reporting procedures if anything goes wrong.
The multi-agency drill, and the continuous training cooperation between the University and the community’s fire department help each person involved with confined space entry understand the importance of following safety procedures each and every time a confined space is entered.
The drill not only tested the confined space procedures and the fire department's rescue skills, it also tested all aspects of the University's emergency reporting system. From the attendant and his direct communications with the worker inside the confined space and the Physical Plant communications area, to the UMass Police Dispatcher and the Amherst 911 operator, all those involved were able to participate in the training exercise.
The O.S.H.A. safety standard, the UMass policy on confined spaces, the continuous training offered around campus on similar safety issues, the fire department’s expertise, emergency response procedures and the workers’ understanding/commitment to their own safety, all play a role in promoting a safe workplace on campus. Our goal is to make employee safety a way of life for all employees while working at the University of Massachusetts at Amherst.
Environmental Health and Safety News
is a publication of Environmental Health and Safety at the University of Massachusetts, Amherst,Massachusetts 01003
Telephone: 1- 413-545-2682
fax: 1- 413-545-2600
send e-mail to: safety@admin.umass.edu
http://www-unix.oit.umass.edu/~safety
Director: Dr. Donald Robinson
Mary E. McEneany, Associate Director
