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Ohio Environmental Protection Agency’s Business Impact Analysis on OAC Chapter 3745-104, “Accidental Releases Prevention Program” (RMP)

The State of Ohio’s EPA performed “Business Impact Analysis” on their version of the Risk Management Plan, as part of an Ohio requirement.  The Ohio EPA RMP rules, which are consistent with federal requirements, became effective August 13, 1999. Ohio EPA received “Delegation of Authority” for the Accidental Release Prevention Program, or Risk Management Plan (RMP) program, effective…...

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Federal EPA considering a “new fee” for facilities under the RMP and SPCC rules

For those of us who live and work in states that have Risk Management Plan enforcement delegation (like Ohio), Risk Management Plan “fees” are nothing new.  But now, Federal EPA is considering charging a “Fee” for those facilities that submit an RMP AND are under federal EPA RMP enforcement. There is no mention if this…...

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EPA RMP citations @ agricultural chemical manufacturing facility (CH4S, C3H9N, C2H7N, NH3 & $72K )

Respondent owns and operates an agricultural chemical manufacturing facility. On or about August 18-19, 2015, EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had greater than 10,000 pounds of methyl mercaptan in a…...

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EPA RMP citations @ fertilizer distributor (NH3 & $137K)

Respondent Ag’s facility includes bulk ammonia storage operations. On or about September 11, 2013, EPA inspected the facility to determine compliance with Section 112(r) of the CAA, 42 U.S.C. § 7412(r), and 40 C.F.R. Part 68. At the time of the September 2013 inspection, Respondent had greater than 10,000 pounds of anhydrous ammonia stored in…...

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FM Global’s NEW Data Sheet shares Loss Histories related to Ammonia Refrigeration Processes

FM Global, my absolute favorite source of RELIABLE and FREE safety information has published a new Data Sheet titled 7-13 Mechanical Refrigeration.  This data sheet and hundreds more are available for FREE (after a very brief registration) to anyone.  A truly MUST have for any safety professional working in an industrial environment!  In their new Data Sheet, 7-13 Mechanical…...

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Ohio’s new Mechanical Refrigeration Code (based on IFC 2015)

In December 2017, the state of Ohio adopted it’s new “Fire Code” which happens to be a revised version of the 2015 International Fire Code.  In November I posted a “heads-up” article about the “proposed” changes to new AMMONIA REFRIGERATION processes built in Ohio after 12/15/2017 and how their relief system(s) will be allowed to…...

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Ammonia release study from INERIS

The French National Institute for Industrial Environment and Risks (INERIS) conducted a study to examine how anhydrous ammonia would behave under a number of different release sceanrios. The main aims of this study were: to analyse the risks represented by facilities using quantities of ammonia of up to a few dozen tonnes to complete knowledge on the…...

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Using the “energy isolation plan” worksheet to meet specific LOTO procedures

OSHA’s Lockout/Tagout (LOTO) standard is pretty clear… ALL servicing and maintenance activities that require the control of hazardous energy require a machine/equipment-specific written procedure. (e.g. 1910.147(c)(4) 1910.147(c)(4)(i) Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section. So does this…...

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42 Incidents (1/29 – 2/10/2018)

Industrial LOTO FATALITYHawkins worker killed at MIS Inc. plant in Phipps Bend (worker, 34, was killed after getting stuck in a large piece of equipment while reportedly trying to dislodge a part that had gotten stuck – as soon as the part was dislodged, the door closed on the worker – death would have been…...

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Documenting the “isolation” of a Permit-Required Confined Space

To continue with my series of LOTO articles this month, I want to discuss how 1910.147 plays into our efforts to enter a Permit-Required Confined Space (PRCS).  Way too many PRCS entry permits have the basic check-the-box statement “All energy sources isolated – YES/NO.”  What the heck is that supposed to meet?  Do our “machine…...

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Is a “Lockout device” more than a Lockout Lock?

As the debate continues about using “clamshells” as a lockout device, our behind-the-scenes discussions continue regarding OSHA’s use of the term “Substantial”. The discussion was so good I asked if I could summarize and post it to keep the discussions going. So once again, here is OSHA’s definition of a “Lockout device”: A device that…...

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