Under the Clean Air Act Section 112(r)(1), the General Duty Clause states: “The owners and operators of stationary sources producing, processing, handling or storing such substances [i.e., a chemical in 40 CFR part 68 or any other extremely hazardous substance] have a general duty [in the same manner and to the same extent as the…...
EPA UPDATES their RMP GDC guidance (April 2020) Read More »
Your inquiry relates to the enforcement of OSHA’s Process Safety Management (PSM) standard, 29 CFR 1910.119, to two hypothetical scenarios you provided that are related to upstream oil and gas production facilities. Background/Scenarios: In your letter, you describe the following scenarios involving natural gas processes that are in the production phase of upstream oil and…...
WorkSafe Victoria is issuing a safety alert highlighting the hazards associated with using small-bore fittings following a number of recent incidents at Major Hazard Facilities (MHF). WorkSafe has recently been notified of three separate incidents involving the loss of containment of highly toxic and corrosive chemicals caused by the use of small-bore fittings for temporary…...
This is a tale of Valve Handle Positions and the assumption the valve was CLOSED based on the position the handle was found in. No Lockout/Tagout and NO VERIFICATION of a Zero Energy State (ZES) before the NG pipe was disassembled. I am not sure why the NTSB makes no mention of “Energy Control” (e.g…....
Line Break gone BAD (Natural Gas and verifying a ZES) Read More »
For those of you that follow my ramblings have heard me rant on about ASME A13.1 and how pipe labeling begins LONG BEFORE a process becomes a PSM/RMP covered process. ALL Hazardous Materials piping has to be labeled! And yes I am well aware of OSHA’s position on pipe labeling and their Globally Harmonized System…...
Pipe Labeling and ASME B13.1 (EPA RMP & $2,700 and $89K abatement costs) Read More »
On March 25, 2008, the State of New Jersey adopted rules requiring facilities regulated under the Toxic Catastrophe Prevention Act (TCPA) Program, which is PSM/RMP to those of us outside of the state of New Jersey, to perform Inherently Safer Technology (IST) reviews. Both OSHA and Federal EPA have tried to incorporate the IST model…...
Inherently Safer Technology Reviews (NJ TCPA) Read More »
Brian Chapin, Compliance Services Manager NOTE: This article is by my good friend and colleague Brian Chapin @ RC&E in Forth Worth, TX. In full disclosure, RC&E has been a corporate member for several years. Brian was gracious in allowing me to post his work directly at SAFTENG as some of you were having issues…...
Compliance in a time of COVID-19 Pandemic Read More »
On June 29, 2005, an operator was involved in the following maintenance activities in the Chloropyridines Complex at the employer’s chemical manufacturing facility. He was returning a reactor vessel to service and WAS ATTEMPTING TO DO A PRESSURE AND LEAK TEST USING CHLORINE GAS. The pipeline was supposed to be pressure tested with nitrogen gas…...
NEVER use the HHC/EHS as your pressure/leak testing media Read More »
On March 13, 2007, Employee #1, a subcontractor, performed maintenance on commercial foodservice equipment. He was in the kitchen area of a single-story restaurant, attempting to locate the source of a refrigerant leak in an ice cream storage dipping cabinet. Employee #1 connected a Nitrogen cylinder to the dipping cabinet’s refrigeration system via a hose…...
A refrigeration system was being installed in a new wing of an ice cream plant in 1984. A leak test was being performed by employee #1 on a “low-pressure tank” which was filled with a mixture of ammonia and air under a pressure of 150 psi. As he squirted a soap bubble solution onto a…...
Leak testing gone bad (Bubble test on NH3 pipe/valve weld) Read More »
At 11:30 a.m. on September 04, 2018, a group of employees was working on a beef processing station. Employee #1 was REPLACING A DEFECTIVE AMMONIA PRESSURE GAUGE FOR A HOT-GAS AMMONIA LINE when he broke off the gauge and associated valve, releasing ammonia into the area and cut/fab floor below. The plant was evacuated and…...
Line Break gone BAD (replacing a defective NH3 pressure gauge) Read More »
The U.S. District Court for the Southern District of New York has approved a consent decree between the U.S. Environmental Protection Agency and the Environmental Justice Health Alliance for Chemical Policy Reform, Clean Water Action, and Natural Resources Defense Council. The consent decree requires EPA to issue long-overdue rules requiring robust hazardous substance spill-prevention and…...
