Chlorine, CAS No. 7782-50-5, is an extremely hazardous substance regulated and listed in 40 C.F.R. § 68.130. As the owner and operator of a stationary source, with respect to the use and storage of ferric chloride and sodium hypochlorite, Respondent has a duty under the General Duty Clause, Section 112(r)(1) of the CAA, to design…...
I like to explain the documentation for our pressure vessels much in the same context as our birth certificates. For every pressure vessel in service today, we must have that vessel’s U-1 Form. And please don’t tell me about the OSHRC decision stating otherwise. I really don’t care what a group of lawyers think about…...
Understanding your Pressure Vessel(s) “Birth Certificates” Read More »
In the USA we use ASME Section VIII, Appendix M-5, and the National Board’s Part 4 when we need to install a block valve before or after a relief valve (RV). In Saskatchewan, Canada their safety authority has a program titled “Pressure Relief Path Stop Valve Control Program“. It is a really nice start to…...
Pressure Vessel “Car Seal” program in Saskatchewan Read More »
These little safety devices cause such big troubles because of pure ignorance. I continue to have silly debates with very smart people about meeting the absolute bare minimums from so many different recognized and generally accepted good engineering practices (RAGAGEPs). As of today, I have written about Hydrostatic Relief Valves 84 times. This week, I…...
ASME B31.3 and Hydrostatic Relief Valves Read More »
This question is one that gets a lot of attention and the debate can become heated. OSHA’s minimum standard, written in 1974, requires the fire watch to be maintained for 30-minutes after completion of welding or cutting operations. But in the past decade, many insurers and standards that are more up-to-date are now requiring that…...
How long should fire watches keep watch after Hot Work ends? Read More »
A sealed, unclassified electrical control enclosure, part of a listed and certified force-ventilated commercial hydrogen processing unit enclosure, exploded when the equipment manufacturer’s technician pressed the machine stop switch to complete the factory commissioning procedure. The technician was forcefully hit by the flying metal panel holding the switch and sustained serious injuries requiring lengthy hospitalization…...
At 2:00 p.m. on May 27, 2019, an employee, 19, was preparing to transfer anhydrous ammonia (NH3) from a bulk storage container to a customer-owned double nurse tank. The employee, who was NOT wearing any PPE, opened a valve on the nurse tank before attaching the transfer hoses, causing pressurized NH3 to be released directly…...
Anhydrous Ammonia incident leads to blindness Read More »
WA-OSHA standards were revised a number of years ago, so they are in “plain English.” These are a GREAT SOURCE of information for anyone looking for a straight forward explanation of OSHA standard requirements. One particular standard that I found helpful was its Hazardous Location (HAZLOC) explanations. These hazardous locations are classified as follows:… Membership...
Where are HAZLOCs normally needed? Read More »
At 4:30 p.m. on November 11, 2020, two (2) employees were in the process of producing batches of a chlorine dioxide generator inside a newly purchased mixer. Emplo yee #1 was killed in an explosion after closing the lid on the mixer to complete the mixing operations. Employee #2 was injured during the rescue attempt…....
OSHA has issued its supplemental VPP assessment questions for 2022. The questions focus on: Leading Indicators & Mechanical Integrity PSM Metrics/Other MOC & PHA Resident Contractors Ammonia Processes and Refrigeration… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
OSHA issues their 2022 VPP Supplemental PSM Questions Read More »
Recently a former client was cited for hiring a contractor who was not qualified for the work they were hired to perform. Also, do not lose sight of the fact that this contractor was NOT cited for any OSHA violation as they did not violate their responsibilities under 1910.119(h)(3), although some may argue they violated…...
Contractor Safety – Evaluation Tip Read More »
Some chemical warehouses and distribution facilities may be failing to properly manage hazardous chemicals as required by federal law. In the past several years, the EPA has visited numerous chemical warehouses and distribution facilities (i.e., companies that process, formulate, blend, re–package, store, transport, and market chemical products) to determine compliance with the Clean Air Act…...
