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EPA RMP citations @ cold storage warehouse for food products (NH3 & $4,800)

On February 5, 2015, EPA conducted a compliance inspection of Respondent’s facility to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.F.R. part 68 under section 112(r)(7) of the Act. The EPA found that Respondent had violated regulations implementing section 112(r)(7) of the Act by failing to comply with the specific…...

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39 incidents & 0 updates (9/16/15)

Over 12,500 exclusive unsafe acts/conditions and accident/injuries photos and over 1,300 ppt’s & doc’s from more than 2,797 contributors!   Many THANKS to my NEW and RENEWING “Partners in Safety“ since 8/2015  since 7/2015 since 2008 since 2009 since 2013 – See more at: http://www.safteng.net/index.php/free-section/safety-info-posts/incident-alerts-2011-2015/3966-58-incidents-1-update-9-7-15#sthash.u7LV12Cn.dpuf Over 12,500 exclusive unsafe acts/conditions and accident/injuries photos and over…...

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MOCs and Technology

Each week I get into some really deep discussion regarding Process Safety and it seems that many of these discussions involve changes and whether the change needs an MOC.  So I thought it would be a good discussion point for us here to toss around.  This scenario actually comes out of a 3-year audit I…...

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Forearmed is Forewarned, REVISING the NFPA 704 may make sense!

Written by David Hatch, Professional Process Safety Engineer (LinkedIn Partner).  This is such an AWESOME idea I asked if I could post this at SAFTENG so more EHS professionals could see it and comment on it. The recent events in China highlight the challenges that on & offsite emergency response teams face when tackling an…...

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DHS CFATS – What needs to be done when a facility is bought or sold?

DHS provides two options when a facility is bought or sold. Option 1: The buyer may assume the facility ID and the submitted surveys of the previous owner. This option is possible under the following conditions:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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2015 Video of the Week #37 (Permit- Required Space Accident – Steam Valve Pit)

This is some AMAZING FOOTAGE of how QUICKLY an entry can go WRONG!  Listen to the worker’s discussing their concerns about entering the pit before the accident occurrs (WARNING – HARSH LANGUAGE).  The Supervisor just orderdd the entrant “to step out for just a minute” when the entrant climbed the ladder and had his head…...

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PRCS energy isolation methods and locking/tagging

When using Blinding/Blanking or Disconnect and Misalignment as an energy isolation method for your PRCS, do these isolation points have to be secured in their safe position with a lockout lock or tagout tag?  In other words, Can I install a blind/blank and not tag it out in the field indicating that it is an…...

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Deciphering HHC/EHS Concentrations for PSM/RMP Applicability

Recently OSHA rescinded all their previous LOIs regarding how to calculate your HHC in your process when it is NOT in pure form.  Since then I have fielded dozens of phone calls and countless emails asking questions about OSHA’s change and how it impacts their process.  OSHA’s new enforcement policy is as follows: In determining…...

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OSHA PSM citations @ food processing facility (NH3 & $71K)

OSHA has cited a food processing facility for 13 serious safety and health violations. OSHA opened an investigation at the company, after receiving a complaint about an ammonia leak. Ammonia is used in the refrigeration process in food production facilities. Inspectors found that about eight pounds of ammonia were released March 3, 2015, from a…...

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Consolidating two (2) Risk Management Plans into one (1)

I recently came across a client who for whatever reasons had two (2) Risk Management Plans submitted for the same group of buildings, structures, equipment, installations and substance emitting stationary activities which belong to the same industrial group, which are located on one contiguous property, which are under the control of the same person (or…...

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Your RMP and Earthquakes, Floods, Tornadoes and Hurricanes

One of the more common errors we come across in RMPs is the listing of earthquakes, floods, tornadoes and hurricanes as “major hazards”.  I can say without hesitation that if your facility is in Omaha, NE that you should not be listing a “hurricane” as a “major hazard” associated with your process.  But you very…...

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