The short and simple answer is YES. It is, without a doubt, a PRCS. This debate is much like the “Is an Evaporative Condenser a PRCS” discussion. This week, I was presenting at the 2020 Refrigerating Engineers & Technicians Association (RETA) virtual conference, and my presentation was “Evaluating Your Ammonia Refrigeration System to determine if…...
EPA has reached an agreement with a Nitrogen manufacturer to resolve federal civil environmental violations of the Clean Air Act’s chemical accident prevention measures and of federal laws requiring timely notification of chemical accidents. EPA identified these violations following an anhydrous ammonia release that led to thirteen workers being injured at the facility in Arizona…....
This is SIGNIFICANT for those who truly believe in the purpose and function of OSHA’s LOTO standard. I was never more disappointed in an ALJ than after they decided to vacate such a clear violation of LOTO. I may have even said, “Why do lawyers/judges make for bad safety professionals.” This fatality involved an apprentice…...
After a boiler exploded at a refinery, OSHA cited the refinery’s owner for violating 29 C.F.R. § 1910.119, which sets forth requirements for the management of highly hazardous chemicals. The Occupational Safety and Health Review Commission (the Commission) upheld the violations. In doing so, it noted that the refinery had previously violated § 1910.119. But…...
Have you ever been told… “it moves too slow to be a hazard”? If you stay in the safety profession long enough, you will be presented with this viewpoint. But LOTO is NEVER about how slow something moves; there is no exemption in the standard for such a thing. Here is a case we can…...
The RMP Amendments finalized on January 13, 2017, included a requirement for owners or operators of a stationary source to engage in emergency response coordination activities (40 CFR §68.93). The regulatory text in 40 CFR §68.10(b) states that compliance with these activities must be completed by March 14, 2018. Because the RMP Amendments were not…...
Program 1 eligibility under 40 CFR §68.10(b) is contingent upon the process NOT having had an accidental release of a regulated substance that led to offsite death, injury, or response and restoration activities at an environmental receptor within five years prior to the risk management plan submission. Additionally, as part of the hazard assessment required…...
As one of its core research focuses, the U.S. Environmental Protection Agency’s (EPA’s) Homeland Security Research Program (HSRP) is interested in refining its tools and methodologies to better characterize the fate and transport of hazardous contaminants during all phases of an emergency response. Atmospheric dispersion modeling is one tool that can be used for effective…...
This safety alert is issued following an incident involving two explosions of ammonia gas cylinders at an ammonia gas filling and bottling plant. The plant has been operating for more than 20 years. The ammonia stock from the suppliers will be stored first in the bulk storage tanks with a capacity of 500 and 900…...
If you’re installing/repairing/modifying your chemical process piping using ASME B31.3 and 31.5, these standards have some strict QA/QA requirements for who can make the welds to join the piping. These welders MUST be qualified in accordance with ASME Code, Section IX, “Welding Qualifications.” ASME Code, Section IX, Part QW-103.1, states that: “Each manufacturer or contractor…...
At the Facility, Respondent produces, processes, stores, or handles more than 10,000 pounds of ethylene oxide. On November 3, 2019, the Glycol 2 Production Unit experienced a release of ethylene oxide. Respondent’s Glycol 2 Production Unit experienced an ethylene oxide release involving the knockout pot D-410 of the Ethylene Oxide Scrubber Process. In response to…...
We have seen hundreds of changes to our businesses since March and many of these changes were needed for worker protection, but recently we came across one such change that had serious potential to cause a bad event! Maybe you have seen the latest and greatest devices for aiding in our “social distancing” efforts. These…...
