I read a disturbing amount of OSHA documents through FOIA requests for research. About 99% of the stuff I read is pretty useless or already known to me from previous reading, but occasionally you come across something that wasn’t redacted that gives you some real insight into the way OSHA thinks. Usually this comes in the form of a NEP question (from their “secret” list) but occasionally it comes from the CSHO (Compliance, Safety and Health Officer) doing the inspection. Below are some pictures from an actual fine – nothing new and exciting in the pictures or fine, really – it’s typical of a 1910.119(j)(5) citation concerning mechanical integrity defects.
What’s interesting in this case is the comment that was made in the 1B:
OSHA course #3430, Advanced Process Safety Management in the Chemical Industries, Spiral Binder training manual, Tab 3, page 28 includes a quote that states “the loss of mechanical integrity due to external corrosion is the single biggest concern in industrial ammonia refrigeration components”.
I don’t know if that’s true or not; I suspect that MI is neck-and-neck with unintended / incorrect operations. What’s important is that OSHA is telling their people it’s true. Now you know!
