The requirements for bonding and grounding of containers during the transfer of Class I flammable liquids are contained in 29 CFR 1910.106(e)(6)(ii). This paragraph does not specifically address plastic containers. However, OSHA issued “OSHA Instruction STD 1-5.14-A” on October 24, 1980 to address plastic containers (NOTE: this STD is NO LONGER AVAILABLE via OSHA.gov). This…...
Illinois Environmental Protection Agency Director has asked the Illinois Attorney General’s office to proceed with enforcement action against Ellinor Trucking and River Rock Logistics, operated out of Lanark. The Illinois EPA alleges an inadequate transfer hose was used when an Ellinor employee prepared to offload anhydrous ammonia to an above-ground storage tank, which resulted in…...
Following the guidance of OSHA and EPA, the industry has attempted to simplify what type of change requires the initiation of the Management of Change system and which type of change is a “replacement in kind” (RIK). Oddly enough, both OSHA and EPA chose not to define the meaning of “change”; instead, they have officially…...
The elements that form the safety culture maturity model have been adapted from the safety culture components listed by the HSE in Reducing error and influencing behavior – HSG48. It is unlikely that these elements will map precisely onto the factors that companies have previously measured in safety culture or climate surveys because there is…...
On January 26, 2006, a factory in Brazil witnessed a significant accident during a pneumatic pressure test involving a tank and pipework. The incident occurred because blind flanges were not used to isolate the pipework connected to the tank. Instead, only the valves were closed. This oversight led to the possibility that one or more…...
The EPA’s Risk Management Plan (RMP) rule was the first time many EHS professionals had ever heard of Emergency Response Planning Guidelines (ERPGs). That was 1999, and still today 2007 there are many EHS professionals outside the PSM/RMP arena who still have not heard of ERPG’s. This article is an attempt to explain what they…...
Emergency response personnel may have never heard the acronym AEGL, but that doesn’t mean it does not play a major role in the decision making process at almost all emergency responses to hazardous materials. AEGL’s and ERPG’s are the most widely used exposure guidelines in emergency responses to hazardous materials. In fact, did you know…...
Temporary Emergency Exposure Limits (TEELs) are guidelines designed to predict the response of members of the general public to different concentrations of a chemical during an emergency response incident. Note: TEEL values are NO longer included specifically in ALOHA, see PACs. TEELs estimate the concentrations at which most people will begin to experience health effects if they are exposed to a…...
Protective Action Criteria for Chemicals (PACs) dataset is a hierarchy-based system of the three common public exposure guideline systems: AEGLs, ERPGs, and TEELs. A particular hazardous substance may have values in any or all of these systems. The PACs dataset implements the following hierarchy when choosing which values to use for the PACs: Final, 60-minute AEGL values Interim, 60-minute AEGL values…...
Public exposure guidelines are intended to predict how members of the general public would be affected (that is, the severity of the hazard) if they are exposed to a particular hazardous chemical in an emergency response situation. The most common public exposure guidelines are: AEGLs (Acute Exposure Guideline Levels) ERPGs (Emergency Response Planning Guidelines) TEELs (Temporary Emergency Exposure…...
I am sure this article will ruffle a few feathers, but honestly, I am surprised and disappointed by that. But I do a lot of work in flammable liquid processing, and this topic always comes up during audits, PHAs, and accident investigations. Some folks will swear that only grounding is “required.” They get this from…...
Comparison of Pressure Vessel Inspection Requirements in the Refrigeration Industry Code Type of Inspection Component Description Inspection Remediation Inspection Frequency IIAR 109 (1997) All pressure vessels If signs of more than mild corrosion should inspect further by a professional engineer or ASME inspector (4.3.5) None listed – Annual ammonia safety check (5.2) – Thorough inspection every 5 years (5.3) IIAR 110 (1993) Including…...
