The state of NJ has developed a Toxic Catastrophe Prevention Act (TCPA) Program Update intended to assist regulated TCPA facilities in understanding how they are impacted by the January 13, 2017, amendments to EPA’s RMP Rule, 40 CFR Part 68. The table indicated the effective dates of the amendments, which provisions are incorporated by the…...
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This Consent Agreement and Final Order serves as notice that the EPA has reason to believe that Respondent violated the General Duty Clause set forth in Section 112(r)(1) of the CAA and the Chemical Accident Prevention Provisions in 40 C.F.R. Part 68 and that Respondent violated Section 112(r) of the CAA. Respondent’s Facility has ceased…...
There are not very many OSHA standards that call out the “trainer qualification(s)” for those who teach on the subject matter, but the HAZWOPER standard does. When a trainer uses the phrase HAZWOPER over and over but does not recognize this is an acronymn that stands for Hazardous Waste Operations and Emergency Response, has no…...
WOW… my LOTO ppt for “Affected Personnel” that I posted earlier this week has caused quite the “back and forth” with too many people/sites. I just assumed that we had a basic understanding of “who falls into the “affected” bucket” and “what they must know”. Affected employees do NOT need to attend a 2-hour training…...
Many of us in the PSM/RMP arena use NFPA 51B as our Hot Work Safety Standard, rather than 1910.252(a) and with that said I thought I should update us on NFPA’s 2019 edition of 51B which includes several key improvements. Probably the biggest changes from the 2014 edition are: the term FIRE WATCH is now officially…...
One phrase that drives me crazy while working with my friends in the Ammonia Refrigeration industry is, “Come on, Bryan; we’re not a refinery or chemical plant; that is unnecessary here.” For example, recently, we were asked to aid in an investigation into a reportable release from a PSM/RMP-covered process, and during our review of…...
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We all know we, as safety professionals, see life through a different lens than most others. But ever since I started seeing these AT&T commercials “Ok is just not good enough” I always go back to my HAZMAT ER days. One of the last ER’s I was called upon for assistance, I was delegated to a…...
Respondent operates an ammonia refrigeration plant and has on-site for use, 130,000 pounds of ammonia for cold food storage. Respondent has submitted and registered an RMPlan to the EPA for its stationary source and has developed an RMProgram accidental release prevention program for the stationary source’s single RMProgram level 3 covered process. On November 8,…...
You are the entry supervisor for entry into a Carbon Monoxide (CO) Tank. Your meter is equipped with an Oxygen Sensor, but it does NOT have a CO sensor. You proceed with your atmospheric testing, as you were told years ago that as long as the Oxygen was over 19.5% that all will be OK. …...
We have an uncontrolled release from our PSM/RMP covered process today, February 5, 2019. We have trained for this day. We have inspected our gear, well most of it, each month for years. We don our LEVEL A suits, which have been pressure tested annually and cared for per every single manufacturer’s requirements. Under our LEVEL…...
