Investigation of March 15, 2018 Pedestrian Bridge Collapse at Florida International University, Miami, FL
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Line Break gone bad (Double Fatality; 70% sodium hydroxide)
One of the PSM/RMP safe work practices I try and get anyone who I cross paths with to implement on ALL of their hazardous materials (regardless of PSM/RMP applicability) is the Line Break and Equipment Opening procedure and permit process. Too often I learn of incidents in processes where the HHC/EHS was under the PSM/RMP…...
EPA announces their RMP enforcement and compliance assurance priorities for fiscal years 2020 to 2023
EPA recently announced its enforcement and compliance assurance priorities for fiscal years 2020 to 2023. There are seven (7) priority areas in total for this period, six of which are National Compliance Initiatives (NCIs), which will be led by EPA’s Office of Enforcement and Compliance Assurance. The one that I follow closely is…… Membership Required...
Compressed Gas Labels and GHS
Many facilities have been struggling with their in-house labeling to meet OSHA’s Global Harmonized Standard (GHS) labeling. I have written on this topic too many times to mention since 2015, but one thing that I am finding and I can not explain is how compressed gas manufacturers have not revised their “shipped container” labels to…...
EPA RMP GDC @ cold storage and distribution facility (NH3 & $40K)
Using “bailing wire” to hold open your deadman valves on oil-pots is a really bad idea… leaving the bailing-wire (e.g. evidence) on the valve after each use is just stupid and shows an auditor/inspector that this is an accepted and continual practice! Another tell-tale indication of cheating a deadman valve is the indentions left in…...
EPA RMP GDC @ cold storage facility (NH3 & $40K w/ 1,865 pound release)
Respondent is a refrigerated warehousing and storage business which experienced a release of anhydrous ammonia on March 29, 2017 that resulted in a response from the local Fire and Rescue department. Following this event, the facility was requested to provide answers to a Chemical Release Questionnaire (CRQ) by EPA, pursuant to CERCLA § 104(e). Respondent’s…...
Ammonia Refrigeration and Tight-Fitting Doors
In the recent OSHRC decision where the ALJ decided that “tight-fitting” doors for an engine room/machinery room doors were not a PSM requirement since “doors” were not part of the covered process. What is confusing is that the company successfully convinced the ALJ that ASHRAE 15 was not their chosen RAGAGEP (even though they stated…...
Setting the record straight on NH3 detectors, the IMC, IFC and ASHRAE 15
With today’s announcement of the OSHRC decision that the IMC was the facilities RAGAGEP and that the IMC does not require detectors, I thought this record needs to be CORRECTED and CLARIFIED, as the ALJ’s understanding of how the IMC and its requirements apply to an ammonia refrigeration process/system. In the decision, the facility successfully…...
Why lawyers/judges make poor safety engineers (OSHRC NH3 PSM decision)
This 2019 OSHRC decision is without a doubt the worst excuse for process safety I have seen since I have been involved with process safety (27 years). This case fails to meet the most fundamental basis of how OSHA’s wrote the standard. Employers get to pick their RAGAGEPs, but when they state the “codes and…...
Can we agree on the terms completely, fully, and absolutely certain?
It seems we, as a profession, struggle to get a consensus on those three words/phrase. For me, it is crystal clear, but for many others I find they wish to have some “room to work” in how they understand these terms to be used. I am often told I read the OSHA (i.e. barebones MINIMUM…...
Flammable gases/vapors, expandable polystyrene, and static electricity (Video)
This video is about as picture-perfect as we can get to show us how static is an ignition source. The plastic rolls (commonly called expandable polystyrene or EPS for short is made with Pentane, a highly flammable CAT 1 gas that is heavier than air and has a Minimum Ignition Energy of just 0.22 mJ. When…...
Does OSHA require a facility to have fire extinguishers?
There are very, and I mean like I can can the number of audits on one hand, rare that we do a compliance audit and not have a 1910.157 finding. And the kicker of it… OSHA gives employers options on how they manage their use of fire extinguishers. Bottom line… OSHA does NOT require that…...