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Did a terrorist group and anhydrous ammonia just validate DHS’s CFATS?

Today has been very interesting, as I have taken several phone calls from security contacts wanting to learn more about Anhydrous Ammonia (NH3) and terrorist attacks, such as suicide car bombs or small missile attacks on pressure vessels holding NH3.  I am not aware of any security alerts issued by US authorities as of this…...

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OSHA S&H Bulletin – Hazards when Purging Hydrogen Gas-Cooled Electric Generators (SHIB 01-22-2016)

U.S. Department of LaborOccupational Safety and Health AdministrationDirectorate of Technical Support and Emergency ManagementOffice of Science and Technology Assessment Introduction Many electric power plants now use hydrogen gas-cooled electric generators versus air- or water-cooled generators. To prevent injury or fatality, employers must ensure hydrogen gas is completely purged from generator housings and bushing boxes before…...

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Does your PSM/RMP utilize “check valves” as a safe guard to PRVENT “reverse flow”? (NRC and API 570)

Check valves are a common piece of equipment within chemical processes; however, often times these specialized valves go years without any inspection or verification they are performing as designed. In some processes, these valves play a pivotal role in PREVENTING the initiation of an incident and can even be the sole layer of protection for…...

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Defining our Safety Systems in our PSI

OSHA’s PSM and EPA’s RMP standards require the employer to develop the Process Safety Information (PSI) regarding each covered process’s “safety systems”. 1910.119(d)(3)(i) Information pertaining to the equipment in the process shall include:… 1910.119(d)(3)(i)(H) Safety systems (e.g. interlocks, detection or suppression systems). §68.65 Process safety information.… (d) Information pertaining to the equipment in the process. (1)…...

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HAZLOC’s and “Fitness Bands” (Part II)

So today my e-mail box overflowed with questions regarding the use of medical devices such as hearing aids, noise canceling hearing protection, and medicine pumps in HAZLOCs.  And yes, there is a solution for these VERY LIMITED opportunities to use a device that is NOT certified for use in these HAZLOCs by a 3rd party…...

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IL Fire Marshal explains state codes and NFPA Life Safety Code

One area that we commonly find during audits and assessments is the lack of complying with the state’s fire, building and mechanical codes.  Often times we find that no one involved in the project(s) were even aware of these baseline state requirements for storing and/or processing hazardous materials.  Now EACH STATE is different, but this…...

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Ohio is revising the State Fire Code for 2017

State Fire Marshal Larry L. Flowers is pleased to announce the initiation of the Ohio Department of Commerce, Division of State Fire Marshal’s (SFM) administrative rule update process for the 2011 Ohio Fire Code (OFC) and associated SFM rules (also known as Ohio Administrative Code sections 1301:7-7- 01 through 1301:7-7-47). The targeted effective date of…...

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HAZLOC’s and “Fitness Bands” (Part I)

This week during my ASSE PSM Training course I had conversations at lunch and after the course around the use of the “fitness bands” that seem to be so popular in “wellness programs” that so many companies are doing.  These wellness plans have a lot of financial incentives to encourage employees to participate.  Both of…...

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2016 Photo of the Week #7 (HAZCOM Labeling)

Bottle #1 – WRONG; “not windex” is not a label and to top it off, look at pic #2.  Sure looks like Windex and it was being used like Windex, because it was Windex!  All joking aside, these types of UNSAFE labeling practices are what lead to those bizarre incidents that show up in the…...

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BEST PRACTICES in Contractor Management (NSC White Paper)

This report summarizes the results of a Campbell Institute research project to aggregate the best practices of world-class organizations in EHS around the management of contractor and supplier safety. The area of contractor safety management is especially pertinent in an increasingly global and complex world that involves work in multiple countries, non-routine work and the use of international and…...

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OSHA PSM citations @ aromatic chemical intermediates manufacturer (ethyl chloride & $72K)

OSHA initiated an inspection on Aug. 4, 2015, under its national emphasis program focused on chemical manufacturers. Inspectors found deficiencies in the employer’s equipment process safety information, process hazard analysis, written operating procedures, contractor safety, equipment inspection and testing along with management of process changes, resulting in the citations. PLEASE NOTE: this OSHA inspection cited…...

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