OSHA updated a 2017 Letter of Interpretation in January 2021 and it is causing quite a stir in the anhydrous ammonia (NH3) fertilizer industry and could have impacts on other industries that use NH3. In this revised LOI, OSHA states… … Therefore, OSHA believes it is possible, and indeed likely, that any given release of […]
I just finished reviewing a draft document that a trade group will be asked to vote to sanction the document as it relates to emergency escape respirators. There was a lot of talk about requiring these escape respirators to carry the NIOSH approval of 14G (vs. the more traditional 23C style respirator). There is talk
At least every five (5) years a Risk Management Plan must be updated. We are seeing a lot of RMP that have been updated in the past 12-16 months that failed to include this in their update. I wrote about this new requirement this past weekend, but now I want to demonstrate the “fall-out” from
Back in February, I broke down the Chemical Safety Board’s new Chemical Incident Reporting Rule (40 CFR Part 1604) and since then we have conducted quite a few safety reviews, emergency response training sessions, and PSM/RMP audits and so far we have not found a single facility that has updated their Emergency Response and/or Emergency
On August 21, 2011, Forty-seven (47) employees, 38 from the primary employer and nine (9) from a secondary temporary agency, were sent to hospitals for treatment of respiratory irritation after being exposed to chlorine dioxide released inside a tomato processing plant. Three (3) employees were admitted for further treatment. The chlorine dioxide release was due
Respondent owns and operates a biopharmaceutical facility that stores and uses anhydrous ammonia in parts of the storage and refrigeration process. Respondent’s storage and refrigeration process does not meet the eligibility requirements for Program 1 under 40 C.F.R. § 68.10(g) and is subject to the OSHA process safety management standard since the process involves ammonia
Respondent is the owner of the meat processing facility which utilizes anhydrous ammonia, a hazardous substance, at the Facility. From December 28-30, 2017, Respondent inadvertently released approximately 1,700 pounds of ammonia due to a faulty isolation valve in the Facility’s refrigeration system (“the Release”). On December 13, 2018, EPA conducted an inspection of the Facility
Respondent is the owner and/or operator of the Facility, which has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. On February 26, 2019, the EPA issued to Respondent a Notice of Potential Violation (“NOPV”), providing notice that the EPA found that Respondent
I have updated my original presentation from many moons ago (2005) for a new Cl2 client using the 2018 Edition of the International Fire Code (IFC) requirements for Storing, Using, Dispensing, and Handling Cl2. SAFTENG members can log in and download the .ppt file which can be used as-is or it can be modified to
I have written about this topic numerous times, and each time it causes controversy among the SAFTENG members. Some members are adamant that we should NEVER allow any “intervening valve(s)” in our pressure relief systems; others have seen it done many times. ASME VIII does indeed allow “intervening valves” before and/or after a Pressure Relieving
At 8:30 a.m. on June 22, 2020, Employees #1, 25, and #2, 47, employed by a piping company, were working on the roof of a three-story food processing company. They were adding new pipe to two (2) new, already installed, 14-inch diameter chilled water lines. The chilled water lines had been pressure-tested with nitrogen.
On May 19, 2021, a supervisor entered a dredging vessel’s ballast tank for an inspection. The supervisor entered the tank without any appropriate Personal Protective Equipment (PPE) and did not check if the confined space was safe. Shortly after entering, he collapsed and passed out. After some time, another worker entered the tank in an
