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GHS does not require SDS to provide NFPA or HMIS labeling information, but when they do – IT MUST BE CORRECT

Over the past four (4) years, I have been involved in an industry that I would have never thought would be some of my Process Safety clients and over these same four years, I have come to feel sorry for an entire industry.  This industry was forced to change to an alternative chemical in order…...

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Using water on an Anhydrous Ammonia (NH3) release

Most emergency responders know that NH3 loves water and well-placed fog pattern will go a long way to “scrubbing” a large NH3 cloud.  But after what we witnessed on Thursday morning, I do wonder if we all know the do’s and don’ts of using water around NH3.  Yes, the incident Thursday was catastrophic and impacted…...

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Liquid ammonia causes frostbite injuries to sanitation employee working on Evaporator drain pan

At 4:00 p.m. on January 5, 2018, Employee #1, employed by an industrial cleaning company, was working at a multiemployer project. He was working from an 8-foot stepladder. He was 2 feet above the ground and monitoring and adding water as necessary to evaporator pans to prevent freezing. The float system on the evaporator failed,…...

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Breaking the plane of a PRCS and the atmospheric hazards from within

OSHA defines entry as: “Entry” means the action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space. Here is…...

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My Aussie friend in safety ROCKS!

Many thanks to Luke Dam, CEO of Safety Wise, for having some fun and making these SAFTENG videos.  If you’re looking for a great incident investigation tool be sure to check out Luke’s company… they are worldwide and they make root cause analysis easy (something many struggle with).    … Membership Required You must be...

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Is there a difference between a vapor and a gas?

ABSOLUTELY!  One of my engineering managers early in my career was the founder of the “engineering geek squad” and was an absolute stickler for details when it came to technical matters.  He always told me I was driving him to the insane asylum with my improper interchangeable use of the terms “vapor” and “gas” when…...

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Did we just experience an NH3 Worst-Case Release Scenario?

This morning, North of Chicago, a 2,000-gallon (8,750 pounds of NH3) nurse tank appears to have suffered a catastrophic failure releasing all 1,700 gallons/8,750 pounds of NH3 onto the road and ditches.   The reason I wonder if this was in the realm of a “Worst Case Release Scenario” is that we had Temps in the…...

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Eeny, meeny, miny, moe (Human Factors)

You’re getting ready to perform your pressure testing and the boss says the six-pack of Nitrogen or Oxygen (he can’t remember which) is out back.  You walk out back and this is all you see… what do you do?  By the way, pressure testing with Oxygen is illegal in most states and VERY UNSAFE in…...

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Anhydrous Ammonia is still the top Toxic involved in RMP 5-year accident histories

Once or twice a year I check on the top 10 or 20 RMP accident histories to find any interesting trends.  I have been doing this for about 12 years and since starting them, Anhydrous Ammonia always finds it’s place as the top Toxic involved.  There are some who want to believe that Anhydrous Ammonia…...

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EPA EPCRA Citations @ food plant after 172 pound release (NH3 and $28K with $6K SEP)

Failing to report a 172-pound release of NH3 (RQ=100 pounds) via an RV to the NRC, SERC, and LEPC in a “timely manner” can be costly! Respondent is a Wisconsin corporation, with a cream cheese and yogurt manufacturing facility. At all times relevant to this CAFO, the Facility was a facility at which a hazardous…...

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EPA GDC RMP citations @ cold storage facility (NH3 & $40K)

This CAFO both initiates and resolves an administrative action for the assessment of monetary penalties, pursuant to Section 113(d) of the CAA. As discussed below, the CAFO resolves the following CAA violations that Complainant alleges occurred in connection with Respondent ‘s storage and handling of anhydrous ammonia at its cold storage and distribution facility: failure…...

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1,800 pound Ammonia release from a CO2/NH3 Cascade Refrigeration System

The business was convicted of one violation under the Environmental Protection Act and was fined $100,000 plus a victim fine surcharge of $25,000, with eight months to pay the fine. Background: The business operates a facility in the County of Lambton, which produces food grade carbon dioxide and is supplied with raw carbon dioxide from a…...

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