Here we have a darn near perfect example as to why OSHA/EPA are now asking businesses with PSM/RMP covered process to “justify” their “maximum intended inventory(s)” of their Highly Hazardous Chemicals (HHC)/Extremely Hazardous Substances (EHS). The business had, at the time of the EPA inspection four (4) 1-ton cylinders of Chlorine in the same room […]
NOTE: This case, as unfortunate as it is, stands in a very small group of State Fire Code violations, and in my memory stands atop of the pile @ $302,500. It is rare for a state to issue code violations and even more rare for the dollar amount to be so high. The one thing
Both OSHA’s and EPA’s process safety standards require operating procedures to contain the “steps required to correct or avoid deviation(s)”, but what exactly does this mean? I really wish OSHA/EPA would have phrased it as “avoid or correct” as putting the words in this order is actual reality. Let’s look at a simple process set-up
UPDATED 8/15/2017 with OSHA Case info: This has now been classified as a “Hot Gas Defrost Valving Error”. On September 11, 2012, Employee #1, a temporary employee was working as a racker-blender at the [wine company], was exposed to anhydrous ammonia, and died of asphyxia. Employee #1 was found in the west hallway 54 ft
FAQ Number: 1784 Date Published: August 04, 2017 Question: Does a facility have to count theft/diversion chemicals of interest in transportation packaging towards the screening threshold quantity if the packaging is on or attached to motive power to include overnight? Answer: Yes. 6 CFR Part 27.203(c) states that facilities must calculate theft/diversion chemicals of interest in transportation
Flaring took place over several days at a bulk propane plant after an unidentified third-party carrier, who is used to haul propane to the site, inadvertently offloaded anhydrous ammonia into propane storage tanks at the site. “It was a driver error on their end, and ultimately there was anhydrous that was in the storage tank
This week we learned of a lawsuit in KS regarding the location of a proposed (actually permitted) cold storage facility. Landowners near the facility have filed suit asking a judge to reverse the county commission’s approval of the 411,000 square feet cold-storage facility near their homes. Neighbors say the plan doesn’t provide the right setbacks or
Just an FYI for those of you who have RMP covered processes in the state of NC. Not much different than what we see with federal inspection data, but there are some interesting differences none the less…
One of the most misunderstood operating procedures in OSHA’s PSM and EPA’s RMP standards is the “Initial Start-Up procedure”. OSHA, nor EPA has offered a lot of written guidance, on this requirement and this has led to a lot of confusion as to why it is called out and how this SOP differs from a
Many thanks to my friends at EPA (and OSHA) for sharing this EPA RMP Checklist specific to Ammonia Refrigeration Processes. Here are the “highlights” specific to NH3 processes. It should be noted that this RMP Checklist specific to Ammonia Refrigeration Processes was developed in conjunction with the International Institute of Ammonia Refrigeration (IIAR) and all EPA Regions. NOTE:
Information is starting to trickle out from the fatal NH3 release last year. This response was performed by one of, if not the best, Fire Department in the country so we can stand to learn a thing or two from their efforts. For those who claim LEVEL A suits are an “overkill” for anhydrous ammonia
