Here is the summary of the Apeals Coourts decision, and this was NOT a red tag program issue. This was an INSPECTION and CORRECTION issue!!! Here is the summary of the decision from the United States Court of Appeals for the Seventh Circuit. Appellants Fun F/X II, Inc. and Cao Enterprises II, LLC (collectively “Fun […]
Performance Influencing Factors (PIFs) is another term, from across the pond, for error traps. You will see me use these terms interchangeably in my HF postings, as I was formally trained to use the term PIFs, but these days it seems we use the term trap. But after spending a year working with an organization
In light of the tragedy in Greece this week, I think it is time to share this video from Lund University’s College of Human Factors Engineering again. Be sure to check out all of Johan Bergström’s videos on YouTube. A term in HFE seldom gets mentioned during accident investigations, as most will say it, “muddies
Flexible hoses are often used to temporarily transfer hydrocarbons and other process fluids to facilitate turnaround activities (clearing equipment, de-inventorying, purging, etc.) and transfer process fluids/products to rail cars and/or/or tanker trucks for shipment. Flexible hoses may also be installed within process piping systems to mitigate the effects of thermal expansion, vibration, or movement during
Facilities should have a written program to ensure flanges are properly made up. Proper makeup of every flange in a piping system is important for reliability. Proper makeup includes:
The ever-controversial “check valve” has now been defined as to when it should be formally included in the piping MI inspection process. As we have discussed many times, if we claim a check valve in our PHA and/or SOP as a “safeguard,” then by all means, this valve has been defacto identified as a “safety
The endpoint concentrations for regulated toxic substances under the risk management program rule (40 CFR Part 68 Appendix A) are listed in units of milligrams per liter (mg/L). Is this equivalent to parts per million (ppm)?
Passive mitigation is defined in § 68.3 as “equipment, devices, or technologies that function without human, mechanical, or other energy input.”
According to the definition of “process” in 40 CFR §68.3, any group of vessels that are interconnected is considered to be a single process. If a stationary source has two interconnected vessels and one contains 6,000 pounds of BUTANE while the other contains 6,000 pounds of PROPANE, is this a covered process under 40 CFR
What does EPA plan to do to verify the accuracy and completeness of submitted Risk Management Plans (RMPs)?
Would the risk management program regulations cover the loading and unloading of transportation containers?
Some landfills collect methane gas and either vent, flare, or store it for subsequent fuel use. Are methane processes at landfills subject to the requirements of the EPA Risk Management Program?
