I see many contractors still attempting to argue that Pressure Testing and Leak Testing are the same tests. This is incorrect, as I have often discussed in my ramblings on this website. This post breaks down the requirements of the most common “leak test,” called the “bubble test.” ASME B31.3 refers us to ASME BPVC, Section V, for how to perform the “bubble test”...

I see this often, a contractor wants to save some $ so they think they can make up their own “bubble-test” solutions. However, not only is this a very bad idea from a QA perspective, it is actually NOT TO CODE, as ASME Section V, MANDATORY APPENDIX I BUBBLE TEST — DIRECT PRESSURE TECHNIQUE, I-1032 BUBBLE SOLUTION contains a very specific and clear statement… (emphasis by me)...

We must battle the need to believe that when a worker has some type of bad outcome, that adverse outcome happens because the worker becamemomentarily incompetent. Our thinking is driven by a bias toward bad things happening because someone did something bad. The bias that worker became stupid is really a strong force in how we learn from events. Thinking that the worker is stupid sends you down the...

B31.3 imposes the following requirements, which are only a few of the elements of a leak testing plan: … HomeRead More »

EPA developed the following key safety measures for the inspection of ammonia refrigeration systems and reviewed them with the International Institute of Ammonia Refrigeration. These are measures that EPA has determined should be in place, regardless of an ammonia refrigeration system’s age or size. This is not intended to be a complete list of important safety measures but rather a subset of easily...

I came across this arrangement, and we debated the position of this valve for 20 minutes, and 7 of us never came to an agreement. We even looked at other tanks that had this valve, and they were different. The valve shown below had its handle reversed as the tank’s ladder was in the way of the valve handle when it was “CLOSED.” The tank next to this one had its handle cut short to...

The 2024 IFC does a nice job of defining our options for work areas where compressed gases that are ASPHYXINATS are stored or used. A client wanted to use Argon, Nitrogen, and Helium in their Labs, and we were asked if this posed a hazard. We took the “inherently safe design” option first, which is to LIMIT the amount of gas that can be inside the room such that if all the gas were to...

The following describes the NIOSH policy for determining the attenuation provided by hearing protection devices for individual workers. This statement updates the 1998 NIOSH Criteria for a Recommended Standard—Occupational Noise Exposure. RecommendationNIOSH recommends employers use individual, quantitative fit testing to evaluate the attenuation received by workers from their hearing protection...

The Standard entitled “Occupational Exposure to Hazardous Chemicals in Laboratories” (29 CFR 1910.1450; the “Standard”) applies to laboratories that use hazardous chemicals in accord with the Standard’s definitions for “laboratory use of hazardous chemicals” and “laboratory scale.” The Standard requires these laboratories to maintain worker exposures at or below the permissible exposure limits...

Question: If an employer has no recordable cases for the year, is an OSHA 300-A Annual Summary still required to be completed, certified, and posted? Answer: Yes. After the end of the year, employers must review the Log to verify its accuracy, summarize the 300 Log information on the 300A summary form, and certify the summary (a company executive must sign the certification). This information must...

At 11:50 a.m. on October 21, 2021, an employee, 51, was assisting his coworkers in troubleshooting the fresh hydrogen fluoride (HF) system to the vaporizer. The employee was looking at an actuator that was across from a whisping flange when the flange failed, and hydrogen fluoride was sprayed on him. The employee screamed, and his coworkers came to his assistance. They escorted the employee to a safety...

This is what drives me crazy! A water treatment plant that falls under EPA’s RMP and yet has made zero effort to comply with the standard gets 11 citations, and the fine was $13,500, which was “adjusted” down to $10,800. This is a PUBLIC entity handling Chlorine (Cl2) in a densely populated area (see Google map screenshot below). The facility failed to develop, implement and manage...