Fire Plant Health & Safety Assessment Report

Prepared by

Julian Kalac, P.Eng

12/6/2012

To: Al LeMaitre, Kirk Daize, Eric St-Amant

C.C.: Jim Anderson

From: Julian Kalac, P.Eng License #90505462

Date: December 6, 2012

Re: Unaddressed Health & Safety Issues by Noble (550 Applewood Crescent location)

Background of reviewer:

I am a Mechanical Engineer and a Professional Engineer (P.Eng.) with over 16 years of

experience in manufacturing with Industrial machines/equipment and processes. My

experience and training have made me very familiar with OSHA/MOL Regulations and

Standards.

OBJECTIVE:

There are 2 objectives in this report:

1. Review the open MOL orders and determine best ways to comply with

them ASAP to prevent MOL fines/penalties

2. Identify non-compliance, including non-compliance associated with

exposure to chemicals and other designated substances, indicate what

measures are necessary to bring the apparatus, structure, protective

element or reviewed process into compliance with applicable sections

referenced in Section 7 of Regulation 851.

Referenced Standards

CSA-Z432-94-- Safeguarding of Machinery

ISO-12100-1&2 Safety of Machinery: General Principles for MachineDesign

CSA A344. 1-05/A344.2-05 (Inspecting & Maintaining Steel Storage Racks)

CAN3-Z180.1-00 Compressed Breathing Air and Systems

CSA-W117.2-94 Safety in Welding, Cutting and Allied Processes

ANSI/B11.19-1990 (R97) Safeguarding Methods

ANSI/Z244.1-1982 Lockout/Tagout of Energy Sources

ANSI/ALI ALOIM-2000 Safety Requirements for Operation, Inspection and

Maintenance

ISO-14121 Safety of Machinery – Principles of Risk Assessment

OHSA Regulation 851, section 7

Ontario's Occupational Health and Safety Act (OHSA) governs workplace health and

safety in this province. Section 7 of Regulation 851 under OHSA deals with "Pre-Start"

Health and Safety Reviews. This type of Health and Safety Review is required in a

factory whenever a process or equipment addition or modification involves any of the

following:

1. Flammable Liquids,

2. Safeguarding Devices That Signal The Apparatus To Stop,

3. Rack Or Stacking Structures,

4. Risk Of Ignition Or Explosion,

5. Dust Collectors,

6. Molten Or Melted Material,

7. Lifting Devices, Travelling Cranes Or Automotive Hoists,

8. Exposure To Substances In Excess Of Regulated Limits. (Oel)

SAFETY ISSUES & MOL orders:

The following are Safety issues in relation to 851 prioritized in severity:

1. Open Mol Order’s Since Nov 11, 2011

2. Lack Of Safe Guarding (Welding & Plasma Cutting)

3. Lack Of Ventialtion Of Toxic/Hazardous Gases/Fumes

4. Types Of Hazards & Max Oel (STEL/ C & Twa) --??

5. Inadequate Plant Lighting

6. Poor Safety System

Lack Of Mandatory Safety Training Ohsa Whimis, Hazmat, Jha, Fire-

Protection, Guarding, Lock-Out/Tag-Out, Etc.

No Monthly Inspections, Inspection Reports, Worker Involvement

Lack Of Hazard Recognition And Awareness

1. OPEN MOL ORDER’S (NOV 11, 2011)

There are 2 open MOL orders since Nov 11, 2011 which are still not addressed

A. In House Racking Validation

B. NOGEO Machine Guarding

In House Racking

Management in charge of MOL orders did not notify Safe Engineering on-time to

come and validate the racks built and as a result the rack needs to be revaluated

for loading requirements.

My preliminary calculations indicate this current rack design can be easily

modified as per Mechanics of Material by adding additional support rods at the

end positions to support the pipes and create uniformed load distribution with

equal supports on all sides (see below)

RACK # 4 IN QUESTION

NOGEO Machine Guarding

As per our meeting Oct 29th, 2012 Maintenance was supposed to provide a fixed barrier

by around the perimeter where the Moving Chuck runs to guard/protect exposure of

moving chuck part and prevent exposure to any pinch-points hazards. This was the

easiest way to guard this area which is secluded in the back of the plant

LACK OF WELDING/PLASMA SAFE GUARDING

The welder is guarded with a make-shift blanket which requires the operator to close and

open every time.

Welding PPE does NOT EXIST. Operators are constantly exposed to radiation and

welding hazards without protection.

CSA Standard Z94.3-07, Eye and Face Protectors, CSA Standard Z94.3-02, Industrial

Eye and Face Protectors, or CAN/CSA-Z94.3-99, Industrial Eye and Face Protectors

PLASMA CUTTER CARDBOARD GUARDING

OPERATOR EXPOSED TO WELDING HAZARDS

DURING OPERATION WITHOUT ANY SAFE GUARDING

The most serious and unsafe condition is the lack of safe guarding of the plasma

Burner/Cutter. IT HAS A CARDBOARD GUARD AS A SHIELD WHICH IS BOTH

HIGHLY FLAMMABLE AND DANGEROUS

THE PLASMA ARC PRODUCES RADIATION AND UV LIGHT WHICH IS EXPOSED

DURING OPERATION WITHOUT PROPER PROTECTION

BURN MARKS ON THE CARDOBOARD

EQUIPMENT SAFETY:

EXPOSED PLASMA CUTTING ARC AND RADIATION

Both Plasma burner carriages are unstable and held by 1 wheel on one side which can

easily be tilted over and cause serious injury to the worker

.

LACK OF VENTILATION Welding Gases/ Fumes

All welding processes produce hazardous gases. Gases are invisible to the eye, and may

or may not have an odour. The heat in both the flame and the arc, and the ultraviolet

radiation from the arc, produce gases such as carbon monoxide, carbon dioxide,

oxides of nitrogen and ozone. Other gases and vapours may be produced as by-

products from the breakdown of solvents or coatings on the metal. Gases used for arc

shielding, or as a fuel, are also given off during welding.

Here are some of the common gases and vapors created during welding

Source Effects and Symptoms

FUMES Aluminum Aluminum component of

some alloys, e.g., Inconels, copper, zinc, steel, magnesium, brass and filler materials.

Respiratory irritant.

Beryllium Hardening agent found in copper, magnesium, aluminum alloys and electrical contacts.

“Metal Fume Fever.” A carcinogen. Other chronic effects include damage to the respiratory tract.

Cadmium Oxides Stainless steel containing cadmium or plated materials, zinc alloy.

Irritation of respiratory system, sore

and dry throat, chest pain and breathing

difficulty. Chronic effects include kidney

damage and emphysema. Suspected

carcinogen.

Chromium Most stainless-steel and high- alloy materials, welding rods. Also used as plating material.

Increased risk of lung cancer. Some

individuals may develop skin

irritation. Some forms are

carcinogens (hexavalent

chromium). Copper Alloys such as Monel, brass,

bronze. Also some welding

rods.

Acute effects include irritation of the

eyes, nose and throat, nausea and

“Metal Fume Fever.”

Fluorides Common electrode coating and flux material for both low- and high-alloy steels.

Acute effect is irritation of the eyes,

nose and throat. Long-term exposures

may result in bone and joint problems.

Chronic effects also include excess fluid

in the lungs. Iron Oxide The major contaminant in all iron

or steel welding processes.

Siderosis – a benign form of lung

disease caused by particles deposited in

the lungs. Acute symptoms include

irritation of the nose and lungs. Tends

to clear up when exposure stops.

Lead Solder, brass and bronze alloys,

primer/coating on steels.

Chronic effects to nervous system,

kidneys, digestive system and mental

capacity. Can cause lead poisoning.

Source Effects and Symptoms

Manganese Most welding processes,

especially high-tensile steels.

“Metal Fume Fever.” Chronic effects may include central nervous system problems.

Molybdenum Steel alloys, iron, stainless steel,

nickel alloys.

Acute effects are eye, nose and throat irritation, and shortness of breath.

Nickel Stainless steel, Inconel, Monel,

Hastelloy and other high-

alloy materials, welding rods and plated steel.

Acute effect is irritation of the eyes,

nose and throat. Increased cancer risk

has been noted in occupations other than welding. Also associated with dermatitis

and lung problems.

Vanadium Some steel alloys, iron, stainless

steel, nickel alloys.

Acute effect is irritation of the eyes,

skin and respiratory tract. Chronic

effects include bronchitis, retinitis, fluid

in the lungs and pneumonia.

Zinc Oxides Galvanized and painted metal. “Metal Fume Fever.” .

GASES Carbon Monoxide Formed in the arc. Absorbed readily into the

bloodstream, causing headaches,

dizziness or muscular weakness. High

concentrations may result in

unconsciousness and death.

Hydrogen Fluoride Decomposition of rod coatings. Irritating to the eyes and respiratory

tract. Overexposure can cause lung,

kidney, bone and liver damage. Chronic

exposure can result in chronic irritation of

the nose, throat and bronchi. Nitrogen Oxide Formed in the arc. Eye, nose and throat irritation in low

concentrations. Abnormal fluid in the lung and other serious effects at higher concentrations. Chronic effects include lung problems such as emphysema.

Oxygen Deficiency Welding in confined spaces, and

air displacement by shielding

gas.

Dizziness, mental confusion,

asphyxiation and death.

Ozone Formed in the welding arc,

especially during plasma-arc,

MIG

and TIG processes.

Acute effects include fluid in the

lungs and hemorrhaging. Very low

concentrations (e.g., one part per million)

cause headaches and dryness of the eyes.

Chronic effects include significant changes

in lung function.

Source Effects and Symptoms

ORGANIC VAPOURS Aldehydes (such as formaldehyde)

Metal coating with binders and pigments. Degreasing solvents.

Irritant to eyes and respiratory tract.

Di-isocyanates Metal with polyurethane paint. Eye, nose and throat irritation. High possibility of sensitization, producing asthmatic or other allergic symptoms, even at very low exposures.

Phosgene Metal with residual degreasing

solvents. (Phosgene is

formed by reaction of the

solvent and welding

radiation.)

Severe irritant to eyes, nose and respiratory system. Symptoms may be delayed.

Phosphine Metal coated with rust inhibitors. (Phosphine is formed by reaction of the rust inhibitor with welding radiation.)

Irritant to eyes and respiratory system, can damage kidneys and other organs.

Table of exposure limits for common Welding substances

Exposure limits

Once the information on possible types of exposure has been determined, the Table of

Exposure Limits for Chemical and Biological Substances should be consulted for the

applicable exposure limit(s).

The employer must comply with the exposure limit for each of the individual

constituents in the welding fume. An additive exposure limit as established in section 5.51

may apply if two or more of these hazardous substances demonstrate similar toxicological

effects. See OHS Guideline G5.51 for further information.

STEL/CEILING COLUMN

This is the short-term exposure limit or STEL, which is defined in section 5.1 of the OHS

Regulation. Note that:

"C" indicates a ceiling limit, which is defined in section 5.1 of the OHS Regulation.

The units ppm and mg/m3 are used as in the TWA column.

Page 12 of 14 Noble Fire PSHR 3 November 2012

Substance [CAS No.] TWA STEL/Ceiling Notations

Acetylene [74-86-2] Simple

asphyxiant

Aluminum metal and insoluble compounds [7429-90-

5] , Respirable, Revised 2008 1.0 mg/m3

Beryllium and compounds, as Be [7440-41-7]

Revised 2009; 2010

0.002

mg/m3 0.01 mg/m3

Skin; S, A1,

1

Carbon black, Inhalable [1333-86-4] Revised 2011 3 mg/m3 2B

CARBON DIOXIDE [124-38-9] 5000 PPM 15,000 PPM

Carbon monoxide [630-08-0] 25 ppm 100 ppm R

Carbon tetrabromide [558-13-4] 0.1 ppm 0.3 ppm

Carbonyl fluoride [353-50-4] 2 ppm 5 ppm

Chromium - Metal [7440-47-3] 0.5 mg/m3

Copper - Fume, as Cu [7440-50-8] 0.2 mg/m3

Fluorides (as F) 2.5

mg/m3

Hydrogen fluoride, as F [7664-39-3] C 2 ppm

Iron oxide dust, as Fe [1309-37-1] 5 mg/m3

Iron oxide fume , as Fe [1309-37-1] 5 mg/m3 10 mg/m3

Molybdenum - Soluble compounds, as Mo, Respirable

[7439-98-7] 0.5 mg/m3

Nitric oxide [10102-43-9] 25 ppm

NITROUS OXIDE [10024-97-2] 25 PPM R

Oxygen difluoride [7783-41-7] C 0.05 ppm

Ozone - Heavy work [10028-15-6] 0.05 ppm

Ozone - Moderate work [10028-15-6] 0.08 ppm

Vanadium pentoxide, Respirable dust and fume, as

V2O5 [1314-62-1] C 0.05 mg/m3 2B

Tin - Organic compounds, as Sn [7440-31-6] 0.1 mg/m3 0.2 mg/m3 Skin

Titanium dioxide [13463-67-7] Revised 2006 10 mg/m3

(N) 2B

Section 5.48 of the OHS Regulation states:

“Except as otherwise determined, the employer must ensure that no worker

is exposed to a substance that exceeds the ceiling limit, short-term

exposure limit, or 8-hour TWA limit

TWA is the employee's average airborne exposure in any 8-hour work shift of a 40-hour

work week which shall not be exceeded."

Page 13 of 14 Noble Fire PSHR 3 November 2012

Training

Several workers, including myself have not received any safety training this year. There are no

training sheets and no information on who has been trained and what is outstanding. There are

MANDATORY OHSA SAFETY TRAINING requirements for all employees. This mandatory annual

training is on the following topics:

1. WHMIS, MSDS, HAZMAT, FIRE PROTECTION,

2. Lock Out Tag Out, Machine Guarding,

3. JHA, Emergency Evacuation, First Aid, Blood Borne Pathogen,etc

CONCLUSION & RECOMMENDATIONS:

It is clear that the current Health & Safety system is not working and the plant is in grave danger

of a serious accident waiting to happen.

The external people in charge of Health & Safety have, for whatever reason, neglected the workers

and their safety and not been able to provide the needed leadership and training to the workers &

ensure their safety concerns are addressed.

The safety belongs to the people of Noble Fire and their leaders, Al, Kirk & the workers. They need

to be able to close out open MOL orders, implement effective the needed action items, which will

make the plant safer without having

PROPOSED SOLUTIONS:

As a Professional Engineer our duty to the public welfare & safety is considered paramount and

are expected to go above and beyond the call of duty if needed.

Therefore I Am Prepared To Take On Additional Responsibility Of The Following Action Items:.

MOL & SAFETY

Work Together With Kirk And Al And Open MOL Orders

Redesign The In-House Rack # 4 And Determine Maximum Load Requirements

Design/Implement The Proper Guarding For The Welders/Plasma Cutters Which Would

Meet Identify The Exposure Substances And Develop Short Term Plans To Meet The

Occupational Exposure Limits

Train The Workers On All The Needed Health & Safety Requirements And Implement A

HAZARD RECOGNITION SAFETY PROCESS Which Enable The Workers To Have A More

Meaningful Role In The Overall Plant Safety.

Production Capacity

Complete the new outlet testing validation/qualification (70% completed)

Finalize the new welding equipment specification and ventilation system which will

ensure proper extraction is designed into the equipment

Look into ways to speed up the capacity improvement in order to reduce the 12 hr shifts

back to 8 hr shifts to reduce exposure time

Overlook the design, build and proper implementation of the new equipment which will

ensure full OHSA compliance

Page 14 of 14 Noble Fire PSHR 3 November 2012

Assist Al and Kirk in all needed Health & Safety, Quality and Productivity action items in

order to make their plant a safer more productive plant

Sincerely,

Julian Kalac, P.Eng.