Emergency Response

OSHRC defines “incidental release”, decon procedures, and respiratory protection for responders

THIS CASE IS NOT A FINAL ORDER OF THE REVIEW COMMISSION AS IT IS PENDING COMMISSION REVIEW This case arose from an anhydrous ammonia (NH3) release that occurred on May 23, 2017, at a Power Plant. OSHA conducted an investigation and subsequently issued a two-item citation for alleged violations with proposed penalties of $18,108.  In…...

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New version of CAMEO now available

Download CAMEOfm 3.5.1 at https://www.epa.gov/cameo/cameo-software Note: If you’re upgrading to CAMEOfm 3.5 from a previous version of CAMEOfm, follow the instructions in the guidance document (provided on the download page) to ensure that you don’t lose your current data. What’s changed in CAMEOfm 3.5.1? Version 3.5.1 resolves an issue in which the program could not…...

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HAZWOPER training credentials – it ALL matters!

There are not very many OSHA standards that call out the “trainer qualification(s)” for those who teach on the subject matter, but the HAZWOPER standard does.  When a trainer uses the phrase HAZWOPER over and over but does not recognize this is an acronymn that stands for Hazardous Waste Operations and Emergency Response, has no…...

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Today could have been hell… what are we starring at?

We have an uncontrolled release from our PSM/RMP covered process today, February 5, 2019.  We have trained for this day.  We have inspected our gear, well most of it, each month for years.  We don our LEVEL A suits, which have been pressure tested annually and cared for per every single manufacturer’s requirements.  Under our LEVEL…...

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Catastrophic failures of SCBA cylinders

On July 11, 1996 a member of the Roxbury Township, Morris County, Fire Department, Firefighter Paul Label, age 29, was in the process of recharging an aluminum 2216 psi SCBA cylinder from the department’s cascade system at about 2038 hours, when it failed catastrophically resulting in serious injuries to Mr. Label. On October 8, 1996…...

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CAMEO updates available

A new version of CAMEOfm is now available.  If you’re upgrading to CAMEOfm 3.5 from a previous version of CAMEOfm, follow the instructions in the guidance document (provided on the download page) to ensure that you don’t lose your current data. What’s changed in CAMEOfm 3.5?… Membership Required You must be a member to access this...

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What is the relationship between reportable quantities (RQs) and threshold planning quantities (TPQs)?

The reportable quantity (RQ) that triggers emergency release notification (Section 304) was developed as a quantity that when released, poses a potential threat to human health and the environment. The RQs were developed using several criteria, including aquatic toxicity, mammalian toxicity, ignitability, reactivity, chronic toxicity, potential carcinogenicity, biodegradation, hydrolysis, and photolysis (50 FR 13468, April…...

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Doing an MOC on changes to your ERT PPE can save you a lot of headaches and maybe a life!

For those who work and live in the world of Process Safety Management, the abbreviation MOC may make you and your colleagues cringe.  And when some “consultant” tells you that using the Management of Change (MOC) process for changes to our Emergency Response Equipment, especially PPE, you are probably thinking… SERIOUSLY?  I cant keep track…...

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Is combustible food dust subject to reporting under EPCRA Sections 311 and 312?

The definition of a “hazardous chemica” l under OSHA HCS includes “combustible dusts”. So, if the facility accumulates 10,000 lbs of dusts at any one time, it is reportable under Sections 311 and 312.  Facilities may want to consult FDA regulations to determine if certain food dusts would be covered under their regulations as food or…...

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What should be included in our emergency pre-planning?

For those of us in the process safety arena, we hear about “pre-planning” almost daily (or maybe we should hear it that often!).  But when we actually start looking into what “preplanning” looks like, most facilities are lost at what they should be doing.  Once again, I turn to the International Fire Code (IFC) to…...

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34,000 pounds of NH3 released over a month results in $664,190 EPCRA and CERCLA citations

At all times relevant to this Complaint, Respondent owned and operated buildings, structures, installations, equipment, pipes or pipelines, and storage containers, located on a single site or on contiguous or adjacent locations, where it deposited, stored, disposed of,  or placed, Ammonia CAS# 7664-41-7.  Ammonia CAS# 7664-41-7 was a “hazardous substance” as that term was defined…...

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