Have you taken the 3 minutes to read OSHA’s expansive Compressed Gas Standard 1910.101? After all, the standard is three sections long and references Compressed Gas Association (CGA) pamphlets that are no longer in print. One of the most requested standards I get from SAFTENG members and clients is for CGA P-1 (1965): Safe Handling…...
Respondent is the owner or operator of the refrigerated warehousing and storage area. Respondent’s refrigerated distribution center includes a Program Level 3 covered process, as provided by 40 C.F.R. § 68.10(d). Respondent uses 74,000 pounds of ammonia (anhydrous), a regulated substance in an amount that exceeds the threshold quantity as part of its covered process…...
On October 26, 2018, Respondent became the owner and operator of the facility upon the completion of a merger. According to Respondent’s RMP, Respondent handles approximately 22,477 pounds of anhydrous ammonia at the Facility. EPA conducted an inspection of the Facility on April 18, 2018, to evaluate the Facility’s compliance with CAA Section 112(r). On…...
On November 30, 2015, an employee entered a large transformer, top cover removed, which had previously been filled with nitrogen. The employee fell unconscious one he/she entered the space. Another employee entered to retrieve the first employee and also fell unconscious. Another employee (#3) followed and also fell unconscious. Employees #1 and #2 died. Employee…...
A 52-year-old male was fatally injured when he was burned due to a flash fire inside a 23’ long x 6’ diameter stainless steel tank. The company was contracted to restore a stainless steel tank so that it could be returned to the dairy process as a Sugar Tank. At the time of the incident,…...
At 1:00 p.m. on July 24, 2019, two (2) employees were filling a tanker truck from a portable bulk container (IBC) when a flash fire occurred. Employee #1 was standing on top of the ethanol tanker truck and his body, clothing, the tanker, tote, and hose caught on fire. Employee #1 attempted to slide down…...
At 3:11 p.m. Employee #1, who had worked with the company for three months as a forklift operator/ repacking, was working alone in the repacking area making a transfer of acetone (flammable liquid) from an elevated 793-gallon stainless steel intermediate bulk container (tote) to a 350-gallon stainless steel tote on the floor. In order to…...
Respondent owns and operates an agricultural storage and supply facility. On August 16, 2016, an accidental release of anhydrous ammonia occurred at Respondent’s Facility when filling a storage tank. The release resulted in the hospitalization of an employee. 22. On or about March 12, 2019, representatives of the EPA conducted an inspection of Respondent’s Facility…...
Many years ago I had an open debate with a “grandfather of refrigeration” on his turf in front of about 30 other refrigeration professionals and the debate was about “flange connections”, ASME B16, and TORQUE and how it all applied to covered processes regardless of what the HHC/EHS was, including anhydrous ammonia in a refrigeration…...
So what is the Assigned-Protection Factor (APF) for an air-line respirator, commonly used inside PRCSs which has, or has the potential to have an IDLH atmosphere? Is it 1,000 or 10,000? I have always been taught/trained that the simple air-line respirator (Pressure-demand/Positive pressure mode) WITHOUT the Auxilary/Back-up cylinder the APF is 1,000, but the addition…...
My January article “What does a “suitable telltale indicator” look like when we have a dual relief system” was a hit as I received numerous requests for information on how to get these special gauges. As I promised each of you in the ammonia refrigeration industry, here is what I have used on my NH3…...
On December 30, 2019, the Bureau of Safety and Environmental Enforcement (BSEE) Inspectors working offshore discovered that a level safety high had been improperly deactivated with a zip tie, resulting in the issuance of a P-103 incident of noncompliance (INC). There have been multiple instances across the Gulf of Mexico in which operators have failed…...
