An old dog is never too old to learn something new. NOTE: This clarification was made in the 2021 edition of NFPA 499. In NFPA 499, the definition of a Class II, Div 1 HAZLOC is as follows: (emphasis by me)… Membership Required You must be a member to access this content.View Membership LevelsAlready a...
As discussed, OSHA is making significant revisions to its Fire Brigade standard. And in the DRAFT version, OSHA establishes a minimum staffing level for working/entering an IDLH atmosphere. Many of you who are part of or manage the fire brigade may recall that OSHA has made room for “judgment” regarding staffing available and performing life-saving…...
This provision of the draft standard would, based on the type and level of service(s) established by the Emergency Service Organizations (ESO), require the ESO to establish minimum medical requirements based on the tiers of responder duties, tasks, and responsibilities. A qualified healthcare professional would perform the medical evaluation of the responders. The medical evaluation…...
In the 90s, I was working a turn-around at a sister facility and learned the niftiest trick related to Double Block and Bleed (DB&B). When the isolation valves and the bleed valve were nearby (i.e., a couple of feet or less) of each other, they would use just a single lock to secure the isolation. …...
A catastrophic incident at an engineering facility serves as a definitive case study in the dangers of improper pressure testing. A technician suffered life-altering injuries when a 335-liter (88-gallon) vessel exploded during a pressure test. The root cause was a fundamental failure in hazard control: the company opted to use compressed air (pneumatic testing) instead…...
Respondent owns and operates an ammonia refrigeration system at its meat processing facility which began operation in February 2019. The ammonia refrigeration system had an initial charge of 17,000 pounds of anhydrous ammonia when operations began, making the facility subject to requirements of Chemical Accident Prevention Provisions in accordance with 40 C.F.R. § 68.10(a) and…...
The proposed OSHA standard will NOT apply to all public sector emergency responders. The scope is limited to Emergency Service Organizations (ESOs) and responders under OSHA’s jurisdiction. ONLY public ESOs that are in state plan states are under OSHA’s jurisdiction and therefore the analysis excludes public ESOs and responders in non-state-plan states. The following states…...
This has been a huge battle in the power generation and semi-conductor industries! To me, it is very clear – as soon as the trailer is “dropped”, meaning the semi that was pulling the tube-trailer has been detached, then that trailer becomes a “stationary process”. EPA has several documents making this point and for those…...
Formaldehyde is not specifically listed with a concentration cutoff, but is listed with the QUALIFIER “solution”. Can the partial pressure exemption be applied to formaldehyde solutions?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
The definition of a process would seem to say that my process is part of the larger company’s process because they are interconnected. Why can’t the larger company just include my process in its RMP?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Must a stationary source owner or operator consider the amount of ammonia present in ammonium hydroxide that is contained in a process when determining whether the threshold for ammonia is exceeded? The list of regulated toxic substances at 40 CFR Section 68.130 includes BOTH “ammonia (anhydrous)” and “ammonia (conc 20% or greater)” but does not…...
Under OSHA’s Process Safety Management Standard, an exemption is provided for the atmospheric storage of flammable liquids. Why has EPA decided NOT to include this exemption under the risk management program regulations?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
