Yoke and Adapter Ruling
Recently an Administrative Law Judge settled a long-standing issue that has been frustrating the sulfur dioxide industry. For the past several years, CalOSHA has been routinely citing facilities that utilize a union adapter to connect to a sulfur dioxide ton container. CalOSHA’s basis for citation has been failure to comply with recognized and generally accepted good engineering practice (RAGAGEP), specifically CGA G-3 – 2017 §9.9 which states in part “Connections to the ton container should be by means of a yoke and adapter or by use of a union adapter connected directly to the valve. The yoke and adapter is recommended.”
Due to the preference for yoke and adapter connections in the wording CGA G-3, CalOSHA had set a precedent that prohibited the use of union adapters even though some sulfur dioxide delivery vendors prefer union adapter connections. In regard to violation for the use of a union adapter, the ruling on 9/18/18, found that CalOSHA “did not meet the burden to prove a violation” and “failed to present evidence of deficient documentation”. Therefore, the citation was dismissed and the facility was allowed to continue employing union adapters for connecting to ton containers.
This is a helpful regulatory clarification for the sulfur dioxide industry and allows for multiple options when connecting to ton containers.
The above information is somewhat correct, EXCEPT that the decision and dismissal of the citations only affect the employer involved. It does not set precedent for all employers who use SO2 in their process. A decision that would be precedenting would be a “Decision After Reconsideration (DAR)” Since there is not a DAR in this case employers should continue to use yokes over unions to remain in compliance with the PSM Standard..
Clyde, Thanks for the feedback. As we discussed in the LinkedIn thread, I fail to see why future owners who receive this citation wouldn’t use the same argument. CGA G-3 allows the use of union adapters and therefore, use of union adapters is consistent with RAGAGEP.