Although anhydrous ammonia is an effective refrigerant, it is also a toxic chemical that can injure or kill people when accidentally released. The death of a worker at a Seafood plant in South Boston in 2016 is the most tragic example recently here in New England. In 2018, the U.S. Environmental Protection Agency (EPA) launched a […]
The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which MUST include: an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date. But do all facilities subject
Must an owner or operator conduct and document a compliance audit at the time of an update required under §68.190 if the update is made within three years of the original RMP submission?
In the world of process safety, every little detail adds up; so as one of my favorite bosses always said… “sweat the small stuff”! This became crystal clear during an incident investigation where a flanged connection was the point of release. Most people look at a flanged connection as a simple means to connect to
Several years ago, we discussed this picture in terms of a Relief Design Basis, the NH3 vent header sensor placement in terms of NFPA 70 HAZLOC, and the risk of doing maintenance/calibration on the sensor when the process is live. As usual, I got some nice feedback, and the usual haters chimed in that I
On March 6, 2018, a pipefitter (49) was hit in the chest by a pressurized 12-inch diameter polyvinyl chloride (PVC) pipe during a hydrostatic pressure test of a fire suppression system. The sudden pipe movement was attributed to a pipe joint connection failure in a buried section of the pipeline. The failure was due to
A chicken processor petitioned for review of a determination by the Occupational Safety and Health Review Commission (the “Commission”) that it violated various regulations of the Department of Labor’s Occupational Safety and Health Administration (“OSHA”). We find no error, so we deny the business’s petition. The Secretary of Labor (“Secretary”) is charged by statute “with
Today, the Indian government released its investigation findings regarding the fatal Styrene release on May 7, 2020, which killed 12 citizens and hospitalized 585 others. This incident, like the many before it, came about by a number of failures the facility/company made in the management of their Styrene inventory. In the light of the root
On January 27, 2019, 12 employees needed transport to nearby hospitals after a a release of 2,100 pounds of anhydrous ammonia. OSHA cited the facility for failing to: Equip an ammonia refrigeration system with a pressure relief device as referenced by the manufacturer’s operating manual; Train technicians to use an alternative over-pressure safety procedure to
Nitrogen… an often misunderstood SAFETY gas that many fear and for good reason! Imagine you have a flammable liquid that has a Flash-PointP<100°F and you worry about static or other ignition sources causing an event inside your storage container… what can I do to lessen the risk of a fire/explosion in the headspace of my
One of the most requested slide deck over the years has been from my 5-Day RAGAGEP course, specific to ASME B31.5, Refrigeration Piping and Heat Transfer Components. The PowerPoint file below is only 12 slides from a 300 slide presentation, but the requirements noted in these 12 slides are often not understood at the plant
7/8/20 UPDATE: this LOI was NOT removed from the OSHA website; it was merely MOVED to the Year 2017 LOI Page (Linked Below). The letter was MOVED without any changes to its content – it was just moved to its proper year. This was merely a recordkeeping move by OSHA to reflect the year the
