Respondent is a Wisconsin corporation, with cream cheese and yogurt manufacturing facility. On April 17, 2017, EPA representatives conducted an inspection of the Facility following a reported release of anhydrous ammonia on September 6, 2016, to determine Respondent’s compliance with Section 103 of CERCLA and Sections 302-312 of EPCRA. During the EPA Inspection, Respondent ‘s…...
Respondent owns and operates a food facility that had greater than 10,000 pounds of anhydrous ammonia in a process at its facility. From the time Respondent first had onsite greater than 10,000 pounds of anhydrous ammonia in a process, Respondent was subject to the requirements of Section 112(r) of the CAA, 42 U.S.C. § 7412(r),…...
To provide a glimpse of what kind of fun I get to have in process safety, I wanted to start a series of chemical profiles of some of the nasty hazardous materials I work with and why so many of my clients are such sticklers for meeting all of the different codes/standards/RAGAGEPS to the letter in…...
OSHA is considering whether to initiate rulemaking to revise its control of hazardous energy standard for general industry. One aim of this RFI is to seek public comment on the modernization of the control of hazardous energy standard without compromising worker safety. OSHA is requesting information from the public on its control of hazardous energy…...
On April 15, 2014, Employee #1, a maintenance technician employed by Solarworld Industries America Inc., and Coworker #1, a tool operator in the plant’s fabrication area, was working at the employer’s solar cell manufacturing facility. Coworker #1 had submitted a work order to repair a leak of liquid hydrofluoric acid (HF). HF is used in…...
The defendant is the operator of a facility that handles, stores, and uses anhydrous ammonia in its industrial refrigeration system. GENERAL ALLEGATIONS At all relevant times, Defendant maintained a refrigeration system at the Facility and that system utilized, processed, handled, or stored anhydrous ammonia, a “regulated substance” under CAA Section 112(r)(3). EPA conducted an inspection…...
Here we have three (3) chemical labels, each one very different from the other and all three have a different agency/organization that oversees their use. All three (3) are for the Category 3 Flammable Liquid Xylene, CAS# 1330-20-7. The question is… Does it matter where/how these three (3) labels are used on containers of Xylene? I…...
For the SAFTENG members This is my 2019 version of the GHS HAZCOM and Behavior of Hazardous Materials training ppt. The course does what I like to call “Compliance to Science”; it covers OSHA’s GHS requirements and then gets into the behaviors of hazardous materials. The course is intended to ensure that users of SDS’s…...
Today, OSHA announced it is requesting information on a possible update to the Control of Hazardous Energy (Lockout/Tagout (LOTO)) standard. The Agency is interested in comments on the use of CONTROL CIRCUIT-TYPE DEVICES to isolate energy, as well as the evolving technology for ROBOTICS. OSHA is requesting information about how employers have been using control circuit…...
A Reminder to Minimize Process Shutdown Related Releases and to Report Releases In a Timely Manner Introduction Unlike some other natural disasters, the onset of a hurricane is predictable and, as a result, lends itself to early preparations for minimizing its effect on a facility. Before hurricane force winds and associated storm surge flooding can damage industrial processes and cause uncontrolled releases of hazardous chemicals, owners/operatorstypically…...
Sprinklers save lives and they save billions of dollars each year from fire losses; however, if a head is activated accidentally, we can suffer serious damage from all the water and the downtime. So protecting our heads from accidental discharge is as important as protecting them from contamination and delayed activation. In this article, I…...
This is a simple, linear cause-and-effect model where accidents are seen as the natural culmination of a series of events or circumstances that occur in a specific and recognizable order. The model is often represented by a chain with a weak link or a series of falling dominoes. In this model, accidents are prevented by…...
