Respondent is the owner and/or operator of a Brewery 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: Respondent operates an ammonia refrigeration plant. Respondent has on-site for use, 160,300 pounds of anhydrous ammonia. Respondent has one RMProgram…...
WTH? Did Haywood just say that? Yep – I am afraid I did and I mean it. Now my personal actions do not reflect that belief, as I am a safety professional and I want every decision you make to be one based on YOUR SAFETY. But as a business, safety can never be #1! …...
Buzz words… oh how I have come to hate them. In my earlier days in this profession, it was called “flavor of the month safety” as we had some catchphrase or “program” we’d implement to try and break through the “mental fog” that caused workers to work unsafely. Then came along the “silver bullet of…...
We do a lot of work in flammable atmospheres so yes we have rather high standards for what “minimal compliance” looks like. We recently came across this situation while performing an assessment for a facility that has suffered from a flash fire months earlier. During our walk-thru of the area (they knew we were coming)…...
Both 1910.178 and 1910.147 have requirements that we periodically evaluate employees’ performance in their ability to perform LOTO and drive PITs in the manner in which they were trained. As I have discussed many times, just doing annual LOTO training without some type of “field verification” that the authorized employees are functioning within the program’s…...
First, let me say this article was written for those who do NOT live in the world of process safety, but yet they do have hazardous materials on-site in some type of bulk system, albeit below the PSM/RMP thresholds. In this posting, I am going to use Propane/LPG as my HAZMAT as there are many…...
The Ohio Environmental Protection Agency, Division of Air Pollution Control (DAPC) has adopted amended rules in Ohio Administrative Code (OAC) Chapter 3745-104, “Accidental Releases Prevention Program” Rules. The rules in this chapter establish Ohio’s Accidental Release Prevention Program. These rules were promulgated after Ohio received the delegation of authority from USEPA in December 1999 for…...
Respondent owned and operated a petroleum refinery with the Standard Industrial Classification (SIC) code 2911. The Facility produces, processes, stores, or handles more than the threshold quantities of flammable and toxic substances identified in 40 C.F.R. § 68.130. The regulated flammable substances that are held above the threshold quantities identified in 40 C.F.R. § 68.130…...
Respondent is the owner and operator of a facility that has five inorganic chemical manufacturing processes, meeting the definition of “process”, as defined by 40 C.F.R. § 68.3. Bromine, ammonia (anhydrous), chlorine, sulfur trioxide, propylene oxide, oleum (fuming sulfuric acid), and sulfur dioxide (anhydrous) are each a “regulated substance” pursuant to 40 C.F.R. § 68.3…....
An explosion and fire that killed a press operator and hospitalized eight other employees at a paint resins and coatings manufacturer could have been prevented had the employer not altered a kettle reactor vessel improperly and then returned the vessel to service after it failed following the alterations, a federal workplace safety inspection has found…....
One of the biggest failures in many “Car Seal” programs is their improper application. I’m not sure where or how this confusion began, but far too many businesses are using car seals well beyond their intended function. Here is a simple way to look at “car seal” programs and how they differ from “servicing/maintenance” programs…...
Respondent is the operator of a chemical manufacturing and distribution facility that ses anhydrous ammonia to produce several chemicals, including ammonium sulfate (made by reacting ammonia with sulfuric acid) and aqueous ammonia (a solution of anhydrous ammonia and water). Anhydrous ammonia arrives by railcar and is distributed through pipes to chemical processes around the Facility…....
