In 2012, I discussed the use of sulfur sticks and asked a question: Sulfur sticks and ammonia leaks… are you in compliance when using these leak detection devices? In 2014, IIAR updated its edition of ANSI/IIAR 2 – Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems, which PROHIBITS their use when charging is being…...
Manufacturer’s Limitations of Sulphur Sticks Read More »
In almost every PHA I have done since 2000, we find safety critical valves or instrumentation with a built-in bypass around them. I understand the need for a bypass WHEN IT IS FOR MAINTENANCE of the device, but in no sane world do we put a bypass around a safety-critical device so that the process…...
Bypassing safety critical valves Read More »
The operators of a global ink and coatings manufacturing company could have prevented an employee from suffering burn injuries from a flash fire that erupted in an industrial mixing vessel containing flammable liquids and vapors by following federal regulations for handling of highly hazardous chemicals. An OSHA investigation determined a flash fire sparked in the…...
OSHA’s Construction Standard for PRCSs specifies several information collection requirements. The following sections describe who uses the information collected under each requirement and how they use it. Employers and employees would use these information collection requirements to identify a confined space at a construction worksite. The purpose of the information would permit employers and employees…...
OSHA’s Construction Standard for PRCSs information collection requirements Read More »
How many code/RAGAGEP violations can you identify? Tip: Code(s) and RAGAGEPs require equipment to be protected against contact with mobile equipment when that contact could lead to an LOPC event involving a hazardous material. Answer(s) below:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
When you see it… (Bollards) Read More »
Imagine trying to build a house today without the proper tools, such as a hammer/nail gun, handsaw/power saw, and tape measure. These are obviously critical to the task being done WELL and EFFICENTLY. Sure, we could build a house without them, but would it be one we would buy and put our family in for…...
[My] Weekly Safety Thought – Building an SMS is like building a house Read More »
In a mature Safety Process/SMS these four (4) elements play a critical role in delivering VALIDATED data to management so that the data can be analyzed and properly responded to in order to INTERVENE in the conditions/actions/attitudes BEFORE an event delivers undesired consequences. The late great Trevor Kletz said it best three decades ago in…...
While anhydrous ammonia has many environmental and operational benefits, it is also an extremely hazardous substance that, if accidentally released, presents a significant health hazard because it is corrosive to the skin, eyes, and lungs. Ammonia is also flammable at certain concentrations in air. The Environmental Protection Agency (EPA) would like to work with facilities…...
Respondent is the owner and operator of a facility. Respondent operates a bulk liquid storage facility and offers a full range of heating, blending, and product services. Various products, such as vegetable oil, chemicals, and petroleum products, are received in tanks for storage and transferred out of the facility to customers. Some of the petroleum…...
EPA RMP GDC citations @ bulk storage facility (Flammable Liquids & $23K w/ $150K SEP) Read More »
Today, OSHA posted its latest LOI. This one was regarding railroad track employees and roadway maintenance groups and the need to provide sanitation facilities for these workers. Question: Do OSHA’s sanitation requirements apply to railroad track employees and roadway maintenance groups that are working along the tracks? Answer: Yes. Under section 4(b)(1) of the Occupational…...
During a recent offshore inspection, a BSEE inspector observed operator personnel installing a 100-foot high-pressure hose, with a Maximum Working Pressure (MWP) of 5000 psi, to test pressure safety valves on pipeline pumps. The hose used was designed for hydraulic fluid and not suitable for high-pressure nitrogen; when nitrogen gas at 2500 psi was injected…...
Pneumatic Pressure Testing gone bad (Wrong Hose used for N2) Read More »
The NY City Bridge got hot because the drive train that moves it overheated, NOT because “climate change” or ambient temperatures caused the bridge to “swell.” I am not a metallurgist, but I did stay at a Holiday Inn Express last week. If this bridge can not operate within its design tolerance because the ambient temps…...
