Disclaimer: I am not a fan of certifications and I carry NONE – a proud safety rebel who has bucked the certification wrap my entire career, so consider the source of this advice. Rather than spending hundreds of hours preparing for the ASP/CSP/OSHT/CSHT/CHMM/CIH how about taking a training course or two from a REPUTABLE provider…...
If you are an NH3 distributor and you’re using the Nitrogen Stabilizers some things have changed that you need to be aware of. First and foremost, see my posting with the Safety Alert from Transport Canada regarding the issues they have found regarding storage and transport tanks and these Nitrogen stabilizers. I have not heard…...
We have all seen it… the person assigned to be the PRCS Attendant (and Fire Watches suffer this infliction as well) are the youngest, weakest, least trained, least experienced, lowest paid, and most incapable person on the job/team. As I have written about before, one of my former employers actually but an age restriction on…...
In 2017 and 2019 I wrote about these Nitrogen Stabilizers and how their introduction into a PSM/RMP covered process would require a MOC and PSSR and I broke down the potential concerns and questions regarding these additives. Now it seems there may be a Mechanical Integrity twist to the use of these additives, as Transport…...
OSHA published a Letter of Interpretation making it clear that we can use “alternative entry” methods such that when the physical hazard(s) can be ELIMINATED OR ISOLATED through engineering controls, AND any atmospheric hazards can be CONTROLLED through forced-air ventilation and continuous atmospheric monitoring, the space may be entered using the alternate procedures set forth…...
Most have seen a full-face Air Purifying Respirator (APR), but just so we are on the same page, I have shared an image of a FF-APR. The serious question I have is… Can this FF-APR be equipped with “escape only” cartridges and be declared an emergency escape respirator? I so NO, but I will be…...
In the past 2-3 years, I have begun seeing Anhydrous Ammonia systems that claim to be built to ANSI K61.1 or CGA 2.1, but somehow these processes do not have the Emergency Shutdown Systems required by these two Recognized and Generally Accepted Good Engineering Practices. So with the help of the Illinois Fertilizer & Chemical…...
My previous article on the Anhydrous Ammonia requirements generated a lot of questions, mostly about how OSHA worded their requirements when it came to Excess Flow Valves, Check Valves, Unloading, and Emergency Shutoff Valves. So this posting I used one of my favorite sources, WA States LNI standards, to present the material in a more…...
This article is being posted in my Hazardous Materials section rather than the Process Safety section because the vast majority of my finds regarding the lack of proper design are almost exclusively in processes that have less than 10,000 pounds. I am hoping that those who read this will understand that what I am going…...
At 12:45 a.m. on December 28, 2019, Employee #1 entered a tanker truck that last held Vinyl Acetate Polymer Residue, a hazardous waste material, and became unresponsive while in the tanker. Employee #2 and Employee #3 entered the tank to rescue Employee #1 and also became unresponsive. Employee #4 entered the tank and was able…...
In several of my articles over the years, I have touched on the additional hazards when working with hazardous materials in an elevated position. In my 2016 Line Break presentation @ ASSE Safety 2016, we made a special point to mention how additional safeguards need to be in place when doing line breaks at elevation. …...
The primary focus of the Emergency Response standard would be to protect workers who respond to emergencies as part of their regularly assigned duties. Examples include: fire brigades/workplace emergency response teams, industrial and municipal firefighters, technical rescuers, emergency medical service providers, etc. A secondary focus of the rule would be to protect those workers who…...
