Most emergency responders know that NH3 loves water and well-placed fog pattern will go a long way to “scrubbing” a large NH3 cloud. But after what we witnessed on Thursday morning, I do wonder if we all know the do’s and don’ts of using water around NH3. Yes, the incident Thursday was catastrophic and impacted…...
Using water on an Anhydrous Ammonia (NH3) release Read More »
Failing to report a 172-pound release of NH3 (RQ=100 pounds) via an RV to the NRC, SERC, and LEPC in a “timely manner” can be costly! Respondent is a Wisconsin corporation, with a cream cheese and yogurt manufacturing facility. At all times relevant to this CAFO, the Facility was a facility at which a hazardous…...
EPA EPCRA Citations @ food plant after 172 pound release (NH3 and $28K with $6K SEP) Read More »
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…...
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…...
New version of CAMEO now available Read More »
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…...
HAZWOPER training credentials – it ALL matters! Read More »
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…...
Today could have been hell… what are we starring at? Read More »
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…...
Catastrophic failures of SCBA cylinders Read More »
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...
CAMEO updates available Read More »
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…...
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…...
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…...
Is combustible food dust subject to reporting under EPCRA Sections 311 and 312? Read More »
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…...
What should be included in our emergency pre-planning? Read More »
