Case Study: Mitigating Multi-Agency Risks

A large industrial gas distribution facility in the Upper Midwest partnered with Justrite Safety Group to conduct a safety walkthrough of their site. Their operation employs a significant workforce and handles a variety of hazardous materials daily. Safety and compliance are essential for maintaining business continuity and employee well-being.

Hazard Analysis

During the assessment critical safety gaps were identified across multiple operational areas. Key hazards represented potential violations that spanned EPA, OSHA, ANSI, and NFPA standards, exposing the facility to significant financial and operational risks.

Hazard	Environment	Key Indicators
Hazardous Waste Storage	Throughout site	! Drums of waste oil and pails were stored without proper secondary containment, risking environmental contamination and regulatory violations.
Electrical Safety	Throughout site	! Electrical panels lacked required signage and clear access, creating shock and arc flash hazards.
Aerosol and Chemical Handling	Throughout site	! Empty aerosol cans were being disposed of unsafely, and hazardous chemicals like acetone were not stored in compliant safety cabinets.
Emergency Equipment	Throughout site	! The eyewash station was frequently clogged and did not meet ANSI standards for emergency use.
Compressed Gas Storage	Throughout site	! Gas cylinders were not adequately secured, increasing the risk of physical injury or explosion.
Workplace Ergonomics and Signage	High-traffic areas	! Insufficient matting contributed to slip, trip, and fall risks, and there was a lack of forklift traffic warning signage in high-traffic areas.

VIOLATIONS & RISKS

Identified potential EPA, ANSI, OSHA, and NFPA violations with fines up to $70,117 per day. Some of the top violations found were:

EPA 40 CFR 264.175
ANSI Z358.1
OSHA 29 CFR 1910.101
NFPA 30/NFPA 1
EPA RCRA 40 CFR 261.23

Why It Matters

Addressing these violations is critical beyond regulatory compliance: Potential fines exceeding $70,000 daily threaten operational viability, while unmitigated hazards risk catastrophic environmental contamination, workplace injuries, or loss of life. Proactive resolution safeguards both human capital and business continuity in the high-risk oil and gas sector, where safety failures can escalate into regional incidents with lasting reputational and financial consequences.

Recommendations

By proactively identifying and addressing these risks, facilities like this one can avoid costly incidents, improve employee morale, and maintain uninterrupted operations.

Secondary Containment: Installed EPA-compliant spill containment pallets and accumulation centers for oil drums and chemical pails.
Electrical Safety Upgrades: Added arc flash and shock hazard signage, floor marking kits, and ensured unobstructed access to all electrical panels.
Aerosol Can Disposal: Implemented an in-house aerosol can recycling system to safely puncture and collect contents, reducing hazardous waste risks.
Emergency Eyewash Station: Upgraded to an ANSI Z358.1-compliant eyewash and face wash station to ensure immediate and effective response to chemical exposures.

Chemical Storage: Provided OSHA- and NFPA-approved safety cabinets for flammable liquids and aerosols, ensuring proper segregation and fire protection.
Gas Cylinder Security: Installed gas cylinder barricade racks for secure storage of compressed gas cylinders and improved labeling for hazard communication.
Workplace Safety Enhancements: Supplied ergonomic matting to reduce slips and fatigue, and installed forklift safety signage to prevent collisions in shared spaces.