Anhydrous Ammonia at Refrigeration Facilities Under Scrutiny by U.S. EPA
This Alert is intended to inform the industry that companies must take responsibility to prevent accidental releases of dangerous chemicals like anhydrous ammonia through compliance with CAA’s Chemical Accident Prevention Program. Evidence gathered by the U.S. Environmental Protection Agency (EPA) indicates that some refrigeration facilities may be failing to properly manage hazardous chemicals, including
A look into what EPA expects in our RMP 3-year audits
Recently EPA issued a Consent Decree in response to a company that had two (2) facilities inspected under the Risk Management Plan Rule (40 CFR Part 68). The document was much like the many others I have posted here; however, this agreement contained a lengthy audit plan that EPA and the company agreed to as
MOCs are much like WORD or EXCEL… they can do so much more than we use them for
For the life of me, I can not figure out the aversion to doing MOCs. I am guessing that my experiences in Petrochem were not the norm, as we used our MOC process for just about everything under the sun. Heck even the QC group used our MOC process. We rarely questioned the value of
PSM Battery Limit Scenario w/ gas cylinders stored within the same building w/ NO passive fire barrier separation (OSHA LOI)
I found this latest Letter of Interpretation regarding PSM Battery Limits an interesting read. The scenario is VERY COMMON and I am so glad OSHA wrote this letter! OSHA reminds us that cylinders stored in the same fire area (e.g. a fire has no passive control(s) to prevent its spread) that ALL of the cylinders
ANSI K61.1-1999 Updated and is now CGA 2.1-2014
The long-awaited update of the ANSI K61.1 “Requirements for the Storage and Handling of Anhydrous Ammonia” is published by the Compressed Gas Association. The new edition was published as the CGA 2.1-2014 edition. The new edition, which is number six in the history of the standard, is considered the recognized and generally accepted good engineering
FM Global Data Sheet beat CSB to punch on Hydraulic Fracturing in NH3 Refrigeration Systems
Those of you that visit SAFTENG often know that I love the FM Global Data Sheets! These data sheets are NOW FREE (and have been for a couple of years). They serve as a GREAT AID in helping facilities understand their hazards and risks associated with all kinds of industries. In fact, although my practice
Chemical Security Program Statistics as of January 5, 2015
The Department of Homeland Security (DHS) continues to strengthen security at the Nation’s high-risk chemical facilities through the Chemical Facility Anti-Terrorism Standards (CFATS) program. Chemical Security Program Statistics as of January 5, 2015: More than 48,000 preliminary assessments were reviewed by DHS from facilities with chemicals of interest 3,598 facilities are currently covered by CFATS
CFATS Corporate Approach (DHS 1/20/15)
Question: How may a corporation with multiple facilities regulated under CFATS request the corporate approach and what benefits does this provide the corporation?
Boiler Operator Attendance EXCEPTION Requirements now mirror a PSM/RMP style management system
A question I am asked nearly each month is… do I have to have a person dedicated to operating the boiler and is this person restricted from performing any other functions while acting as the “boiler operator”? While I am not a “boiler expert”, most of my clients have industrial size boilers associated with their