Hazardous Materials

EPA recognizes “bollards” as a safeguard

From at least August 20, 2025, until June 12, 2026, Respondent failed to ensure process equipment located in areas accessible to vehicles was protected from heavy machinery by means of bollards, guardrails, or other acceptable forms ofprotection, as required by 40 C.F.R. 68.65(d)(2), which directs owners and operators to ensure that equipment complies with recognized…...

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If the source container is metal and the receiving container is nonconductive, do the bonding and grounding requirements apply? (OSHA Archived LOI and CPL)

Bonding and grounding two non-conductive containers would seem unnecessary, since non-conductive materials are insulators and therefore cannot conduct current through them. However, static electrical charge can be generated when two dissimilar materials pass quickly by one another (i.e., liquids flowing through pipes, even air). OSHA recognizes that there are many factors that affect the size…...

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Visual Aid for Teaching PPM and % by Volume

I am always trying to give my students a visual when I begin talking about IDLH values. It’s one thing to say that Chlorine’s IDLH is 10 ppm and explain what that means within the training room. So I have been playing with some AI sources, mainly Google Gemini and ChatGPT, to create visual aids…...

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How can we fill a plastic gas can that is 5 gallons or smaller with gasoline and not have a flash fire every time?

I use this example in my HAZMAT and flammable liquids training courses. To give away the magical answer (LOL), it’s all about the UEL of gasoline, which has a Flash Point of -50F and a vapor pressure of 450 mm Hg or 8.7 psig!… Membership Required You must be a member to access this content.View...

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Is bonding and grounding an effective control when transferring non-conductive flammable liquids?

The short answer is no. While bonding and grounding are absolute regulatory requirements under OSHA 1910.106 and are foundational safety measures in flammable liquids safety, they are insufficient on their own when transferring non-conductive (e.g., conductivity < 50 pS/m) flammable liquids like toluene, xylene, benzene, or ultra-low sulfur diesel. This is a classic process safety…...

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What is the “NO GO” for an NH3 release?

In all my years of training, responding, and now teaching others, my NO-GO has always been 10,000 ppm. But why 10,000 ppm? Is this a Haywood thing, or is this based on science and the limitations of most direct reading instruments (DRI)? Well, here are the facts as to why 10,000 ppm should be your…...

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The need for REMOTE Emergency Shutdown

I thought this image was a good way to show why Codes and standards for hazardous materials such as NH3 REQUIRE REMOTE Emergency Shutdown Systems. For example, CGA 2.1 states the following:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA updates the HAZCOM CPL (Secondary Container Labeling)

In May of this year, OSHA issued an updated version of its CPL-02-02-079, Inspection Procedures for the Hazard Communication Standard (HCS 2024). In this updated CPL, OSHA explains the requirements for “secondary containers”, which has become a hotly contested practice for unknown reasons. I have spent the past 2 years trying to correct the “internet…...

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Did you know… Elevation impacts Flash Point

As elevation increases, atmospheric pressure decreases, which means flammable liquids can “flash off” at lower temperatures. I always use the “Mile High Stadium” example in my training courses to explain this principle as it relates to Boiling Points and Flash Points. But NFPA explains it like this…… Membership Required You must be a member to...

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Operator seriously injured when sprayed by liquid NH3 after failure of flexible rubber hose

A process worker and colleague were preparing for a scheduled maintenance task in the ammonia storage area of a processing plant. As part of a routine purging operation, the process worker connected a flexible rubber hose to a purge connection point via a coupling. The purge hose was charged with nitrogen and the valve was…...

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The smallest change without an MOC review results in a serious fire

Transferring a flammable liquid, even in small quantities, can have very serious consequences. A former client who handles large quantities of flammable liquids had an event a number of years ago that was caused by what many never recognized as a “change,” especially one that would lead to such a serious event. Take a look…...

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BOLLARDS BABY! (NH3 release caused by PIT)

NOTE: I have no idea how a PIT can strike a PSV on a pressure vessel, but this is what was reported to have happened. A forklift at the facility struck a pressure relief valve on a 60,000-pound NH3 tank that contained 14,000 pounds of ammonia, the Sacramento Fire Department said. One person was injured…...

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