Emergency Response

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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Does your Emergency Response Plan use DOE’s “Protective Action Criteria” (PAC)

The Department of Energy has a little-known database that is a goldmine for emergency planners and responders.  This database is called the Protective Action Criteria for Chemicals (PACs), and it uses a hierarchy-based system of the three (3) exposure guideline systems:  Acute Exposure Guideline Levels (AEGLs) Emergency Response Planning Guidelines (ERPGs), and Temporary Emergency Exposure…...

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What it’s like to have a 14″ NH3 pipe suffer a 24″ long stress fracture on your roof

UPDATED 2/16/2021 with OSHA Case File A couple of KEY POINTS in this EMA’s report out to the County Supervisors: Two weeks before this incident the County had conducted a drill at another NH3 facility that involved a rooftop NH3 leak (PREPAREDNESS) The release came from a 14″ diameter suction line on the roof of…...

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OSHA puts the HAZWOPER standard on the UPDATE schedule

OSHA currently regulates aspects of emergency response and preparedness; some of these standards were promulgated decades ago, and none were designed as comprehensive emergency response standards.  Consequently, they do not address the full range of hazards or concerns currently facing emergency responders, nor do they reflect significant changes in performance specifications for protective clothing and…...

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Physical and Health Hazards Cross-Walk for EPCRA Tier II Reporting

I know we are past the 2018 reporting deadline (March 1st), but last week (4/10/18) EPA posted a beneficial tool for those of you who work with EPCRA Tier Sheets.  EPA and OSHA did an excellent job developing this cross-walk worksheet to assist facilities in comparing OSHA’s original and new physical and health hazards adopted…...

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Changes to U.S. EPA Tier II Hazardous Chemical Inventory Reporting effective for the March 1, 2018 Filing Period

In 2016 EPA revised some of the EPCRA reporting requirements based on OSHA’s revision of their Hazardous Communications Standard (now called the GHS).  This revision involved the hazard categories in the regulations at 40 CFR part 370 for reporting under Sections 311 and 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA). On March 26th, 2012, OSHA revised its…...

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When the wind is your friend and you can watch NH3 boil

This is video footage from an anhydrous ammonia (NH3) leak (liquid leak) and does an excellent job of showing how NH3 will behave when released as a liquid, with a boiling point of -28ºF.  The videographer may not have known how close he was to “death” while shooting his/her footage, but the wind was his…...

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