Maybe I’m just old school, but is it just too much to ask for: a well written safety procedure, one that is written and analyzed with a safety pro and the worker(s) who do the actual work, that management will fully support the procedures everyday-everytime, including on holidays that fall on a Sunday, and employees…...
Respondent operates an ice rink facility with an ammonia refrigeration system. The System uses or used anhydrous ammonia, a chemical that is listed pursuant to Section 112(r)(3) as an “extremely hazardous substance” and that is subject to the General Duty Clause. In March of 2022, Respondent’s response to an Information Request issued by EPA revealed…...
Respondent is the owner and/or operator of an animal slaughtering facility where anhydrous ammonia is used in refrigeration systems. The Respondent conducted an offsite consequence analysis in early 2022, showing that the population inside the worst-case scenario radius includes 961 houses, and 2,851 people could be exposed to this release. The Respondent also conducted an…...
Respondent is the owner or operator of an ingredients facility with greater than 10,000 pounds of ethylene oxide in a covered process and greater than 10,000 pounds of trimethylamine in a covered process at the Facility. From the time Respondent first had onsite greater than 10,000 pounds of ethylene oxide and/or trimethylamine in a process,…...
The Respondent owns or operates a chemical distribution facility where the respondent has used or stored more than 15,000 pounds of formaldehyde. 40 C.F.R. § 68.25(a)(2)(i) requires the owner or operator of a stationary source to analyze and report in a Risk Management Plan (“RMP”) the worse-case release scenario that is estimated to create the…...
On June 7, 2022, an employee working as an environmental engineer was replacing two failed pumps in a pump station. Two coworkers connected the new pumps to electricity, and the employee lowered the pumps into the vault. It was noted that the pumps weren’t working correctly, and water was pumped from the space. The employee…...
Northwest Airlines Flight 255, a McDonnell Douglas MD-82, crashed in Romulus, Michigan, shortly after takeoff from Detroit Metropolitan Wayne County Airport on August 16, 1987, at about 8:46 p.m. It killed all six crew members and 148 passengers, and two people on the ground. There was only one survivor, it was a 4-year-old girl who sustained…...
November 20, 2022 was the anniversary of Chemical Facility Anti-Terrorism Standards (CFATS) regulations. And although it is not as well known as OSHA’s PSM and EPA’s RMP standards, it is a standard that many PSM/RMP practitioners deal with, so I thought it would be fitting to look at the CFATS numbers…… Membership Required You must...
In a recent training course, the EPA answered the “One Big Question”… (one that I have written about many times) Does the facility rely on emergency responders to stop the release of the regulated substance(s)? If the facility answers Yes, they are saying the local first responders will respond and stop the release. This means…...
Here are the six (6) triggers that will get your RMP Inspection Case referred to DOJ:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
This Safety Alert addresses the importance of verifying atmospheric conditions in fish holds on commercial fishing vessels. There are specific hazards associated with the use of brine dip solutions, a common substance used in the industry. Brine dip combined with standing water can produce dangerous levels of hydrogen sulfide (H2S). The U.S. Coast Guard is…...
Human Factors means HUMANS making decisions- OUR roles as safety professionals is to chart a path to SUCESS IN SAFETY, rather than hoping they avoid failure. Safety is NOT about luck. Safety is the confidence that there is a path to safety success – CULTURE is convincing the workers that the best path is the…...
