Respondent owns and operates an ice-making plant that uses anhydrous ammonia in a refrigeration “process”. In 2016, Respondent filed a Program 3 RMP for the Process and reported that it used 22,000 pounds of anhydrous ammonia. In accordance with 40 C.F.R. § 68.10(a) and (f)-(h), the Respondent’s use, storage, and handling of anhydrous ammonia in […]
Respondent is a limited liability company that operates as a public warehousing facility. The term “have a general duty in the same manner and to the same extent as section 654 of title 29 [of the U. S. Code]” means owners and operators must comply with the General Duty Clause in the same manner and
I like to explain the documentation for our pressure vessels much in the same context as our birth certificates. For every pressure vessel in service today, we must have that vessel’s U-1 Form. And please don’t tell me about the OSHRC decision stating otherwise. I really don’t care what a group of lawyers think about
We are working to implement a formal root cause and corrective action process for a client. The industry has a very different view and approach to what I have come to know over the last 30 years as Human Factors. I think my friends “down under” are reading my mind or my articles at SAFTENG
As we approach The National Safety Stand-Down To Prevent Falls in Construction (May 2-6, 2022) I am reminded of how some view “Elimination” within the Hierarchy of Controls. The number of postings on social media calling for the “Elimination of falls” in the construction industry has me asking… can this actually be done? One such
In the USA we use ASME Section VIII, Appendix M-5, and the National Board’s Part 4 when we need to install a block valve before or after a relief valve (RV). In Saskatchewan, Canada their safety authority has a program titled “Pressure Relief Path Stop Valve Control Program“. It is a really nice start to
These little safety devices cause such big troubles because of pure ignorance. I continue to have silly debates with very smart people about meeting the absolute bare minimums from so many different recognized and generally accepted good engineering practices (RAGAGEPs). As of today, I have written about Hydrostatic Relief Valves 84 times. This week, I
On November 25, 2020, an explosion and fire occurred at an industrial facility in Houston BC. The facility utilizes a system incorporating a large natural gas-fired air heater to dry wood fiber material for the purpose of wood pellet production. The facility had recently been experiencing issues with operating conditions with the dryer system. The
As safety professionals, we typically spend a great deal of time training workers. However, the time we are given to conduct this training is shrinking; so we need to be SMART in how we develop our content AND deliver it. The “learning pyramid” has been around as long as I have been alive and it
A forklift operator at an industrial site was filling a liquid propane cylinder on the forklift and also heard a hissing sound. The operator then started the forklift and a flash fire explosion occurred at the forklift and propane dispensing system. The facility is an industrial wood processing plant with a propane dispensing system. Propane-fuelled
This question is one that gets a lot of attention, and the debate can become heated. OSHA’s minimum standard, written in 1974, requires the fire watch to be maintained for 30-minutes after completion of welding or cutting operations. But in the past decade, many insurers and more up-to-date standards now require that fire watches be
New York State Department of Environmental Conservation (DEC) announced the execution of two Orders on Consent with SHPP US, LLC, (known as “SABIC”), in Selkirk, including $322,400 in penalties and required facility improvements. These enforcement actions resolve violations after a September 2020 incident at the SABIC plastics manufacturing facility that released approximately 22,057 pounds of
