In the world of Human Factors, we have a saying, “failing safely,” which translates into… all humans make mistakes – it’s our job to identify those error/mistake traps and design work to lessen those error opportunities. In Process Safety we used to use the phrase “cascading failures”, which is the opposite of “failing safely.” In […]
As of July 28, 2023, Congress has allowed the statutory authority for the Chemical Facility Anti-Terrorism Standards (CFATS) program (6 CFR Part 27) to expire. Therefore, CISA cannot enforce compliance with the CFATS regulations at this time. Due to this lapse in statutory authority, CISA cannot enforce compliance with the CFATS regulations. Access to the
Notice I used the word “necessary” and not the word required. In my experience, a PSSR saved my ass plenty of times when OSHA/EPA did NOT require it. To my knowledge, OSHA (nor EPA) have defined the word “facilities” in the context they used it in 1910.119(i)(1)… (emphasis by me) 1910.119(i)(1) The employer shall perform
At 11:09 a.m. on December 19, 2022, an HVAC contractor was installing a heating unit when a coworker operating a scissor lift struck a NH3 pipe/valve that caused a release of ammonia. The contractor, 68, was overcome by ammonia and died. The lift operator was hospitalized for treatment for his exposure to ammonia.
Today I saw our local Natural Gas service provider discussing installing an Excess Flow Valve with my neighbor. So naturally, that caught my ear, so I mossed over to learn more. It seems that most Natural Gas service providers are offering the installation of an Excess Flow Valve on the feed to homes. Of course,
At 11:00 a.m. on May 23, 2019, an employee removed a regulator from a chlorine gas cylinder to perform yearly maintenance and repacking. When the employee attempted the close the shutoff valve, the valve malfunctioned and stopped turning while still slightly open without the employee’s knowledge. When the employee removed the regulator, chlorine gas escaped.
Two workers were injured on an offshore platform while installing a skillet, the steel circular joining plate inside a section of piping. The incident occurred while the workers were on scaffolding and unbolting a 10-inch flange (Figure 1). After determining the skillet was the wrong size, the supervisor instructed a third worker to join the
Uninterruptible Power Supply (UPS) is a pretty common backup power supply in industrial settings where “power failure” can lead to the loss of control systems, emergencyshutdown systems, and emergency mitigation systems. But like ALL SAFEGUARDS we take credit for in our Hazard Analyzes, these UPS must be in our mechanical integrity program for testing/validation regularly
A process covered under 40 CFR Part 68 is eligible for Program 1 requirements if it meets all of the criteria listed at 40 CFR §68.10(b). One of those criteria is that the distance to a toxic or flammable endpoint for a worst-case release assessment is less than the distance to any public receptor. Are
Performance of the hazard assessment required under 40 CFR Part 68, Subpart B, includes analysis of both worst-case release scenarios (40 CFR §68.25) and alternative release scenarios (40 CFR §68.28). In each of these analyses, passive mitigation systems may be taken into consideration. If a tank has a “double wall,” does that qualify as “passive
I use propane as a raw material in my manufacturing process. I lease the tank from the propane supplier. The supplier does all the maintenance. My staff never work on the equipment. What should I do?
Which states have been granted a delegation of EPA’s authority to implement and enforce the risk management program rule?
