UPWARDS and UNOBSTRUCTED – say it again! UPWARDS and UNOBSTRUCTED. Two simple and very clear terms that so many struggle with when it comes to Relief System Designs. Here is a horizontal discharge of a relief valve on an NH3 vessel. The discharge height is ~20′ but we can see how the gas is dispersing. …...
This past week a small ice plant in São Luís – State of Maranhão, Brazil experienced what can only be described at a “catastrophic failure” of a pressure vessel. Details of what/how this happened are sketchy at best; however, the video shows us what anhydrous ammonia can do when it is “blocked-in”. I am assuming this…...
This past week a small ice plant in São Luís – State of Maranhão, Brazil experienced what can only be described at a “catastrophic failure” of a pressure vessel. Details of what/how this happened are sketchy at best; however, the video shows us what anhydrous ammonia can do when it is “blocked-in”. I am assuming this…...
Most safety and emergency response personnel understand that an Emergency Action Plan (EAP) is intended to cover the reporting, sounding an alarm, and evacuating and accounting for everyone. But most will say 1910.120(q) applies ONLY when the facility has a “response team”, but is this correct? Way back in the 1990’s OSHA stated the following…...
This is an excellent video that takes us through the progression of an ammonia (CAT 2 Flammable Gas) explosion. A contractor working in the engine room reported the smell of ammonia @ 6:04 a.m. A maintenance worker entered the engine room at 6:24 a.m. and did not smell/see/notice anything unusual!!! I am guessing they did…...
Jack Rabbit: Chlorine Properties is a 28-minute video that uses footage from the Department of Homeland Security’s Jack Rabbit release trials to demonstrate chlorine’s dispersion properties. The video covers the following topics: Introduction Dispersion Pressure Differentials, Phase Changes, and Thermal Considerations Density Different Atmospheric/Land Conditions… Membership Required You must be a member to access this...
We should be doing MONTHLY inspections on our LEVEL A suits (regardless of manufacturer) and this month, those of us who use DuPont Tychem® Level A suits will need to take some special actions due to a change that DuPont implemented several years ago. Effective September 1, 2013, DuPont transitioned to Pirelli valves for all…...
MEMORANDUM FOR: REGIONAL ADMINISTRATORS, STATE PLAN DESIGNEES THROUGH: AMANDA EDENS,Acting Deputy Assistant Secretary FROM: PATRICK J. KAPUST, Acting Director,Directorate of Enforcement Programs SUBJECT: Enforcement of 29 CFR 1910.29(f)(1)(ii)(B) and 1910.29(f)(1)(iii)(A): Heights of Handrail and Stair Rail Systems This memorandum replaces the memorandum issued on June 10, 2019, on this subject, and provides guidance to Compliance…...
One of the biggest flaws in the OSHA’s and EPA’s process safety standards is their expectations of how contractors are to be evaluated. Yes, of course, hiring contractors with good safety programs and good safety performance is CRITICAL, but way too many facilities are only looking at the safety numbers and programs. And that is…...
Following the August 2012 fire and chemical release at a San Fransico Bay Area refinery, the Governor of CA formed the Interagency Working Group on Refinery Safety to examine ways to improve public and worker safety through enhanced oversight of refineries, and to strengthen emergency preparedness in anticipation of any future incident. The Interagency Working…...
Respondent is the owner and/or operator of a Brewery which uses, handles, and/or stores more than a threshold quantity of anhydrous ammonia, a regulated substance, as specified at 40 C.F.R. §§ 68.115 and 68. 130. Pursuant to CAA section 112(r)(7), Respondent is required to prepare and implement a risk management program to detect and prevent…...
Question 1: Does the HCS apply to universal waste, which is included within the definition of hazardous waste and subject to 40 CFR 273? Response: No. As noted in the background section, per 29 CFR 1910.1200(b)(6)(i), the HCS does not apply to hazardous wastes regulated by the U.S. Environmental Protection Agency (EPA) under the Resource…...
