Betting this was just under 10 pounds. That’s a RQ joke as the RQ for Cl2 is 10 pounds – CLEARLY we have exceeded that in this event. (But you never know!) All jokes aside, this is a big one. People wanting to know why it’s taking so long to get an “all clear” 2-hrs…...
Large-scale (10K pound) Cl2 Release in Freeport, TX Read More »
Respondent produced, used, or stored ammonia at the Facility and released a reportable quantity of an EHS, ammonia. On or about August 31, 2022, a “release,” as that term is defined by Section 329(8) of EPCRA, of ammonia in excess of 100 pounds occurred at the Facility (the release). As a result of the information…...
EPA EPCRA/CERCLA citations ($65K) for 350 pound NH3 release from refrigeration process Read More »
A 45-year-old senior fire captain is facing charges after authorities say he improperly conducted respirator fit tests for firefighters and lied about it. He is charged with forgery and tampering with records, the County Prosecutor’s Office said Friday. He signed reports stating the tests had been completed when they had not been finished between Jan…....
Fire Captain falsified Fit-Test Records and is facing charges Read More »
Respondent is the owner and/or operator of the Facility, which operates a chemical storage and distribution facility. The respondent had on-site storage for 50,000 pounds of cyclohexylamine, 1,800,000 pounds of chlorine, 1,500,000 pounds of sulfur dioxide (anhydrous), 265,000 pounds of ammonia (anhydrous), 350,000 pounds of ammonia (concentration 20% or greater), and 17,000 pounds of hydrofluoric…...
EPA RMP Citations (NH3 & $105K) Read More »
The PSM standard requires the employer’s PHA team to evaluate human factors during its process hazard analysis. CCPS defines human factors as “a common term given to the widely-recognized discipline of addressing interactions in the work environment between people, a facility, and its management systems.” The basic principle of assessing human factors is to determine…...
Learning Human Factor mistakes from others Read More »
The Management of Change (MOC) section of the PSM standard requires the employer to implement written procedures for managing changes (except for replacements in kind) to processes involving chemicals, technology, equipment, procedures, and changes to facilities that affect a covered process. The MOC procedure requires descriptions of the technical basis for the change, impact on…...
Learning MOC mistakes from others Read More »
OSHA has identified the following mistakes found at PSM facilities nationwide. These mistakes were identified at refineries; however, almost all can be found within any PSM-covered process. I have revised OSHA’s wording so that we can ALL learn from these mistakes. PLEASE do not fall for the old trap of “Bryan, we are not a…...
Learning MI mistakes from others Read More »
Employers can use the Safety Pays Individual Injury Estimator to assess the impact of occupational injuries and illnesses on their profitability. This program uses a company’s profit margin, the average costs of an injury or illness, and an indirect cost multiplier to project the amount of sales a company would need to generate to cover…...
Safety Pays Individual Injury Estimator Read More »
The following NFPA and ANSI standards, in whole or in part, are to be incorporated by reference into proposed rule 1910.156, per 29 CFR 1910.6. See 29 CFR 1910.6(a)(1). Provisions in the proposed standard are drawn from, or consistent with, the following NFPA standards, but these standards are not proposed to be incorporated by reference:…...
Standards Referenced in OSHA Proposed Rule 29 CFR 1910.156 (Emergency Response) Read More »
This unfortunate event is the result of the same failure seen in nearly every industrial facility on the planet… a guarding interlock gets bypassed, and a worker pays an unimaginable price for the failure. Sometimes it’s the worker(s) who bypass the interlock, and other times they are the unknowing victim of the bypass. Here is…...
The saga of the bypassed safety interlock Read More »
I usually do not waste time posting the Expedited Settlement Agreements, as these cases are typically minor record-keeping violations with low-dollar amount citations. However, one thing that irks me is how public utilities receive lenient treatment regarding the amount they pay for violating the EPA’s RMP regulations. And to make matters worse, they dare to…...
EPA RMP citations @ Water Treatment Plant (Cl2 & $2K) Read More »
Respondent is the owner and/or operator of a facility that operates an ammonia refrigeration plant with 39,000 pounds of anhydrous ammonia. Respondent has one RMProgram level 3 covered process, which stores or otherwise uses anhydrous ammonia in an amount exceeding its applicable threshold of 10,000 pounds. On July 18, 2023, the EPA conducted an on-site…...
EPA RMP Citations @ food facility (NH3 & $135K) Read More »
