Respondent owns and operates an agricultural chemical manufacturing facility. On or about August 18-19, 2015, EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had greater than 10,000 pounds of methyl mercaptan in a…...
Respondent Ag’s facility includes bulk ammonia storage operations. On or about September 11, 2013, EPA inspected the facility to determine compliance with Section 112(r) of the CAA, 42 U.S.C. § 7412(r), and 40 C.F.R. Part 68. At the time of the September 2013 inspection, Respondent had greater than 10,000 pounds of anhydrous ammonia stored in…...
FM Global, my absolute favorite source of RELIABLE and FREE safety information has published a new Data Sheet titled 7-13 Mechanical Refrigeration. This data sheet and hundreds more are available for FREE (after a very brief registration) to anyone. A truly MUST have for any safety professional working in an industrial environment! In their new Data Sheet, 7-13 Mechanical…...
In December 2017, the state of Ohio adopted it’s new “Fire Code” which happens to be a revised version of the 2015 International Fire Code. In November I posted a “heads-up” article about the “proposed” changes to new AMMONIA REFRIGERATION processes built in Ohio after 12/15/2017 and how their relief system(s) will be allowed to…...
The French National Institute for Industrial Environment and Risks (INERIS) conducted a study to examine how anhydrous ammonia would behave under a number of different release sceanrios. The main aims of this study were: to analyse the risks represented by facilities using quantities of ammonia of up to a few dozen tonnes to complete knowledge on the…...
OSHA’s Lockout/Tagout (LOTO) standard is pretty clear… ALL servicing and maintenance activities that require the control of hazardous energy require a machine/equipment-specific written procedure. (e.g. 1910.147(c)(4) 1910.147(c)(4)(i) Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section. So does this…...
Industrial LOTO FATALITYHawkins worker killed at MIS Inc. plant in Phipps Bend (worker, 34, was killed after getting stuck in a large piece of equipment while reportedly trying to dislodge a part that had gotten stuck – as soon as the part was dislodged, the door closed on the worker – death would have been…...
To continue with my series of LOTO articles this month, I want to discuss how 1910.147 plays into our efforts to enter a Permit-Required Confined Space (PRCS). Way too many PRCS entry permits have the basic check-the-box statement “All energy sources isolated – YES/NO.” What the heck is that supposed to meet? Do our “machine…...
As the debate continues about using “clamshells” as a lockout device, our behind-the-scenes discussions continue regarding OSHA’s use of the term “Substantial”. The discussion was so good I asked if I could summarize and post it to keep the discussions going. So once again, here is OSHA’s definition of a “Lockout device”: A device that…...
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Wearing a baseball cap while performing hot work may make you look cool, but just watch this video and we can see what OSHA was trying to prevent with… 1910.252(b)(3) Protective clothing General requirements Employees exposed to the hazards created by welding, cutting, or brazing operations shall be protected by personal protective equipment in accordance with the requirements of…...
Anyone who has worked with ASME/API pressure vessel codes knows the basic language used to describe Relief Valve (RV) discharge locations… “discharge to a safe location”. This requirement applies to ALL relief devices on all types of equipment and although OSHA does not have a specific standard on relief devices and their design, they will use…...
