American Cylinder and Safety, LLC
|Posted on November 29, 2018 at 1:10 PM|
I am always amazed when asked the question; “Why do I need refresher training, when I have been doing this job every day?” Many people have the belief that if they do a job day in and day out, they should not need refresher training or that the need for this training does not apply to them. For the record, I want to state that this attitude or belief is patently false. A lack of refresher training opens an organization to liability, fines, and other issues.
As a quick refresher, any compressed gas over 29psi, is considered HAZMAT by the federal government. Any employee that fills, handles, or is likely to be affected by this HAZMAT is considered a HAZMAT Employee and the DOT has specified the training requirements this type of employee.
Title 49, Code of Federal Regulations (CFR), Part 172.704 lists the various types of training required for hazmat employees. This training includes function-specific training, general awareness training, and training in safety and security awareness. 49 CFR 172.704 also requires that employees retake their training at least once every three years. Depending on the organization it may also require that employees undergo recurrent training for their regulations even sooner. It is up to the individual organization to conduct this training (either through their own trainers or through an outside training agency) and certify that their employees have received this training.
As the saying goes, there is a method to the madness. Refresher training plays an important part in the health and safety of the employees. One of the most important reasons for refresher training is that federal regulations can change since the last time training was conducted. The DOT reviews and revises 49 CFR every year. Likewise, other governing agencies update their own regulations, normally on an annual basis. Occasionally, if the change is vital to the safety of an employee, the regulations might be updated outside of the normal review period. Some of these changes may be small, while others can be significant. However, it does not matter how major or minor these alterations may be. Anyone involved in the hazardous materials transportation process must know all of them. Remember, ignorance of the law is not an excuse when it comes to an investigation. Refresher training allows them to stay on top of everything that is new and different in this field.
In addition to educating the HAZMAT employee to new regulations, refresher training helps to reinforce the training they have received in the past. Occasional refresher training helps the employee remember information and tasks that are vital to their job, yet might not be performed every day. By both updating the employee’s knowledge, and reinforcing skills and knowledge previously learned, safety of an organization is strengthened. This safety benefits everyone, to include employees, employers, shippers, receivers, and even innocent bystanders. Because of this, recurrent training should be looked at as an investment in the business, and a properly trained employee as a valuable asset to the workforce.
An organization should properly manage the training of employees and schedule refresher training when needed. American Cylinder and Safety is happy to help. We can provide training in all of the required types. We can accomplish this through coming to your facility, or through online options. Contact us today to schedule your training or answer your questions.
|Posted on November 16, 2018 at 2:55 PM|
Entities that work with compressed gasses fall under the jurisdiction of both the Department of Transportation (via 49 CFR) and the Occupational Safety and Health Administration (OSHA) via 29 CFR. Because of this, employers are mandated to conduct training for their employees dictated by both government entities. The result of not complying can be extremely expensive in the event there is an accident where an employee is injured. Employers who have hazardous materials in their workplace are required to train employees on safety data sheets, labels, and the associated hazards of the materials. Recently, a company in Alabama was fined for just this violation. Legend Directional Services LLC, was fined $28,445 by OSHA when an investigation into the death of an employee found that a lack of training resulted in the rupture of multiple cylinders. Help to keep your employees safe, and your pocketbook intact, by conducting the mandated training, and keeping it up to date. American Cylinder and Safety can assist in this training either at your facility, or through online training. Contact us for more information.
|Posted on October 30, 2018 at 10:35 AM|
Luxfer has finally released its position on Eddy Current Testing of Luxfer cylinders made of 6061-T6 Aluminum Alloy. The short version is that Luxfer does not require or recommend Eddy Current Testing of cylinders made of 6061-T6. These are cylinders manufactured by Luxfer after 01 July 1988. This position reflects the official position released by Catalina Cylinders a few years ago. The full position statement and release can be found here:
Eddy Current testing of cylinders manufactured out of 6351-T6 Aluminum Alloy is still required by law as mandated in 49 CFR.
|Posted on October 20, 2018 at 2:25 PM|
A new tool in the tool box for anyone dealing with hazardous materials is the new online chemical database that has been launched by the Occupational Safety and Health Administration. This electronic database allows users to search for chemicals by CAS number, name, or even partial names. When you select a chemical, you find information that has been complied via multiple sources and even links to outside organizations and their chemical libraries.
Most importantly, for the responder, it lists vital information on each chemical such as the boiling and melting points, physical properties, exposure limits, IDLH information, and upper and lower explosive limits.
This resource is free to the public and a great reach back and identification tool. You can access it at www.osha.gov/chemicaldata
|Posted on October 6, 2018 at 9:40 AM|
I have been involved in HAZMAT response and training for over 10 years and it still amazes me that there is still a lack of awareness in regards to Safety Data Sheets (SDS). Many employees are still not aware of the purpose for these sheets, or what an important role they play during an incident involving chemicals.
Within the last 5 years, the OSHA standards regulating workplace safety revised the Hazard Communications Standards (HCS) in order to realign it with foreign countries who use the Global Harmonization System (GHS) and assist in the clarification and communication of the dangers involved with chemicals. One of the results of this revision was the reorganization of the old Material Safety Data Sheet (MSDS) into the new Safety Data Sheet format.
The SDS is used as a primary information source of the hazards of a chemical and includes such subjects as environmental hazards, first aid procedures, accidental release measures, and safety precautions. Utilizing this information, facility managers can employ safety programs, develop mitigation measures for accidental releases, and develop appropriate safety training for employees. More importantly, the SDS provides critical information to first responders and medical personnel to rapidly and effectively treat individuals that have been exposed. Employees need to be aware of where they can locate these data sheets, and employers have a duty to ensure their workers are knowledgeable as to what chemicals are stored at the workplace and where to acquire this data.
|Posted on June 29, 2018 at 9:40 AM|
Two popular models of SCUBA tanks have had thier special permits renewed by PHMSA (USDOT). The USDOT has confirmed that both SP14932 and SP12076 have been renewed and the updated permit can now be downloaded as a .pdf document on the PHMSA website. Because these permits have been renewed, normal hydrostatic testing can resume and these cylinders may remain in service.
|Posted on July 25, 2017 at 1:10 PM|
These days, no subject is without controversy or drama and that includes the cylinder manufacturing industry. Recently, the Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) issued Special Permit 16320 to Digital Wave Corporation to allow “the extension of the 15-year service of certain carbon fiber reinforced aluminum-lined cylinders (DOT-CFFC) that are used in self-contained breathing apparatuses by firefighters and first responders.” The PHMSA website states that under this new Special Permit 16320, issued to Digital Wave Corporation, “cylinder life can be extended an additional 15 years through the use of Modal Acoustic Emissions (MAE) testing.” In accordance with the special permit, PHMSA “may authorize extensions of service for DOT-CFFC cylinders in five-year increments when they are re-qualified by MAE testing” and “the incremental extensions may enable the cylinders to remain in service for up to 30 years.”
Luxfer Gas Cylinders, a manufacturer and supplier of breathing air cylinders to SCBA manufacturers, has issued a formal statement concerning the life extension of DOT-CFFC carbon composite cylinders by means of Modal Acoustic Emissions testing.
To summarize Luxfer cylinders statement; Luxfer was never involved in this new testing program by Digital Wave corporation. Because they were not involved in this program dealing with their cylinders, Luxfer cannot accept responsibility or liability for use of their cylinders beyond the 15 year service life that they were designed for. Additionally, Luxfer will not warranty cylinders past their 15 year service life.
Scott Safety has publically stated that if these cylinders are re-qualified under this new method, it will invalidate the NIOSH approvals for the air packs.
Meanwhile Digital Wave Corporation has publically stated that their method is safe, and the only reason that cylinder manufactures disagree is because they fear the loss of a revenue stream.
Who is right? That is for the user to decide.
|Posted on January 23, 2017 at 3:00 PM|
Two new regulations for re-qualification of cylinders will become mandatory starting Monday - January 23, 2017.
New Re-qualification period for DOT4 series cylinder such as Propane
Option to now use test labels rather than stamps on all cylinders, except for 3HT series.
Section 180.209(e) of 49CFR
(e) Proof pressure test. A cylinder made in conformance with DOT Specifications 4B, 4BA, 4BW, or 4E protected externally by a suitable corrosion-resistant coating and used exclusively for non-corrosive gas that is commercially free from corroding components may be requalified by volumetric expansion testing or proof pressure testing every 10 years instead of every 5 years. When subjected to a proof pressure test, the cylinder must be carefully examined under test pressure and removed from service if a leak or defect is found.
This is a rule change, previously Propane 4B specification cylinders were requalified by:
- Volumetric Test every 12 years
- Proof Test every 7 years
- External Visual Examination every 5 years
With this rule change, Propane 4B specification cylinders are now requalified by:
- Volumetric Test every 10 years
- Proof Test every 10 years
- External Visual Examination every 5 years
Section 180.213(c) of 49CFR
(c) Requalification marking method. The depth of requalification markings may not be greater than specified in the applicable specification. The markings must be made by stamping, engraving, scribing, or applying a label embedded in epoxy that will remain legible and durable throughout the life of the cylinder, or by other methods that produce a legible, durable mark.
Previously the use of labels to mark the re-qualification information on a cylinder was only permitted on Composite cylinders and fire extinguishers. This rule change now allows labels to be used on all cylinders except the 3HT cylinder which specifically states you must use Low Stress stamps.
|Posted on November 18, 2016 at 5:15 PM||comments (4)|
An issue has been found with the 2016 ERG’s that were part of the first batches printed.
On page 13, ROAD TRAILER IDENTIFICATION CHART, Compressed Gas/Tube Trailer, gives a guide page of 137. This is incorrect and should state Guide 117. This was discovered and reported several months ago and apparently this issue was corrected in the latest printed versions of the ERG.
Please make sure your personnel are aware of this issue when utilizing the ERG’s.
|Posted on September 12, 2016 at 12:20 AM||comments (8)|
If you’re a first responder, or involved with Hazardous Materials in any way, you should be familiar with the Emergency Response Guidebook (also known as the ERG or Orange Book). The 2016 edition was released this year with some significant from the previous 2012 version. The current changes are:
-The addition of a flow chart the describes “How to use the Guidebook”
-A area has been included for local emergency response numbers to be written in.
-A section has been added for the Global Harmonization System (GHS) of classification and labeling of chemicals.
-Addition of all new dangerous goods listed in the UN Recommendations on the Transport of Dangerous Goods up to the 19th revised edition.
-In the table of initial isolation and protective action distances (Green Pages) there is the addition to table 3 of “Estimating wind speed from environmental clues”.
These changes definitely improve the ERG and make initial responses actions safer. I highly recommend any user of this manual pick up the latest copy and flip through it for familiarization or review.