The Chain of Failure The catastrophe centered on the unloading area for liquefied petroleum gas (LPG) tanker trucks and unfolded over a matter of minutes. Botched Connection: Around 1:00 a.m., a driver attempted to connect an omnidirectional loading arm to the tanker’s discharge outlet. The connection procedure was complex, and the driver failed to secure…...
OSHA uses the General Duty Clause (GDC), Section 5(a)(1) of the OSH Act as a “gap filler” to cite employers for recognized chemical hazards when a specific standard (like the Process Safety Management standard, 29 CFR 1910.119) does not technically apply. There are some critical legal limitations on GDC Enforcement: OSHA’s ability to invoke 5(a)(1)…...
Not having an ammonia detection system, which had been cited the previous year, also as a GDC; however, it seems the business was sold, and the new owner was cited for not addressing the detection system…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
As I said in my previous posts on GDC PSM citations, this is new territory for me and OSHA enforcement. I was always taught (and by some very sr. OSHA personnel) that OSHA can not use the GDC to enforce hazards for which OSHA already has a standard for. It was OSHA’s “carrot and stick”…...
Apparently, they can and have. Here are some GDC citations for an NH3 refrigeration process. These were part of a large release inspection that included some HAZWOPER and HAZCOM citations. My only guess is that these GDC citations are tied directly to the NH3 release, but I have not yet seen the field notes, so…...
The 2027 edition of the standard includes new definitions for the terms battery energy storage system and lithium-based battery with associated annex material. Updates have been made in Section 6.2 to align with NFPA 1 regarding 1A and 1B flammable gases and to further clarify that Category 1B has a lower flammability than Category 1A…...
A Hierarchy of Controls Analysis (HCA) is a highly structured risk-mitigation methodology. It is specifically required under CalARP Program 4, which applies to petroleum refineries operating within California. While a standard Process Hazard Analysis (PHA) identifies risks and lists existing safeguards, an HCA forces a facility to systematically evaluate whether hazards can be eliminated or…...
A Safer Technologies and Alternatives Analysis (STAA) is a systematic risk management evaluation used in process safety engineering to identify and assess ways to make a process inherently safer. Instead of relying solely on add-on safety equipment or administrative procedures to manage a hazard, an STAA asks: Can we eliminate or significantly reduce the hazard…...
OSHA is proposing several updates to its Respiratory Protection Standard (29 CFR 1910.134) as part of a broader deregulatory effort to reduce employer compliance costs and provide greater flexibility, without compromising worker safety. Here are the key changes currently on the table:… Membership Required You must be a member to access this content.View Membership LevelsAlready...
Respondent is the owner and/or operator of the Facility, which is a “stationary source” and has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. At its Facility:(a) Respondent operates an ammonia refrigeration plant.(b) At all times relevant to the violations alleged, Respondent…...
At all times relevant to this CAFO, Respondent operated a facility that utilizes anhydrous ammonia to produce approximately one-quarter billion frozen burritos for distribution nationwide each year. On July 20, 2022, EPA performed an inspection of the Facility to evaluate compliance with the CERCLA Section 103, EPCRA Sections 304-312, and CAA Section 112(r). Based upon…...
Yes, this is a very OLD standard, but there is really nothing to replace it, as it still holds true today as much as it did in 2003. I have discussed this standard several times, and I ALWAYS share it with clients who are a tad lost on what the role of their safety professional(s)…...
