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
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
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
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
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
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
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
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
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
For those who deal with emergency planning and response know all too well about EPCRA’s Tier Sheets, most notably Tier II sheets that facilities submit annually so as to inform the emergency response community of their hazardous materials and extremely hazardous substances on site. These Tier sheets have been around since 1986 and are still a
OSHA has cited a power plant and it’s security services provider, for $43,458 in total proposed penalties, following a release of anhydrous ammonia at its Gibsonton facility. On May 23, 2017, OSHA responded to the incident and determined that the ammonia release occurred when a relief valve activated after a pipeline became over pressurized. As a
