Hazardous Materials

Anhydrous Ammonia Emergency Shutdown for Hose Severance

In the past 2-3 years, I have begun seeing Anhydrous Ammonia systems that claim to be built to ANSI K61.1 or CGA 2.1, but somehow these processes do not have the Emergency Shutdown Systems required by these two Recognized and Generally Accepted Good Engineering Practices.  So with the help of the Illinois Fertilizer & Chemical…...

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Anhydrous Ammonia unloading and tank requirements in laymen terms

My previous article on the Anhydrous Ammonia requirements generated a lot of questions, mostly about how OSHA worded their requirements when it came to Excess Flow Valves, Check Valves, Unloading, and Emergency Shutoff Valves.  So this posting I used one of my favorite sources, WA States LNI standards, to present the material in a more…...

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Anhydrous Ammonia unloading design specs in 1910.111

This article is being posted in my Hazardous Materials section rather than the Process Safety section because the vast majority of my finds regarding the lack of proper design are almost exclusively in processes that have less than 10,000 pounds.  I am hoping that those who read this will understand that what I am going…...

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When bollards fail!

All bollards have limitations.  Most are designed to stop a 12,000-pound vehicle traveling at 10-mph.  Most non-commercial vehicles will weigh far less than 12,000 pounds; however, 18-wheelers will weigh far more than 12,000-pounds.  These are the bollards that are the ones that are 4″ steel pipes filled with concrete and buried at least 3′ into…...

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Fueling stations, bollards and fake bollards

Anyone who follows my ramblings knows that I am a big fan of bollards.  I have written about them and shared dozens of incidents where a properly designed and installed bollard saves the day and more often than not I am sharing incidents with “fake” bollards where something was destroyed because the bollard was IMPROPERLY…...

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Where does it require I have an Oxygen Monitor when I use liquid Nitrogen?

OSHA may use their General Duty Clause (GDC) to enforce their desire for employers to have Oxygen monitor(s) in areas where inert cryogenics are stored and used.  But I like to use codes/standards (e.g. RAGAGEPs) to drive my safety engineering of these hazardous processes, even though they are not PSM/RMP covered processes.  To do this…...

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Liquid Nitrogen and the IFC (Part I)

This week we saw OSHA issue two willful and three serious violations totaling $122,602 to a sperm bank for bulls (cattle) after an employee was asphyxiated while filling freezers with Liquid Nitrogen.  And back in 2017, we saw another sperm bank, this one for humans, have a Nitrogen incident which claimed the life of a…...

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Alarming Trends Found on Fixed Gas Detection Systems (USCG Safety Alert)

The United States Coast Guard issued a Marine Safety Alert after they discovered three (3) separate Liquefied Natural Gas (LNG) carriers with issues with their fixed flammable gas detection systems that resulted in the issuance of deficiencies and delay of cargo operations. While witnessing tests, multiple sensors measured outside the tolerances established by the manufacturer…...

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Separation Distances in NFPA Codes and Standards (Final Report)

Have you ever wondered where all the “separation distances” we see in OSHA Standards, NFPA Codes, Fire Codes, etc. come from?  Who came up with them, what are they based on, etc.?  All legitimate questions and you are NOT alone!!   Many of these requirements have historical undocumented origins. Guidance, which may inform a sound technical…...

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When ventilation is your engineering control, it should meet IMC Section 500

When we have a hazardous material that poses either a physical hazard such as a flash fire/explosion or a health hazard we need to manage this hazard using our hierarchy of controls.  The first control is to see if we can use a “safer alternative” which we call “Elimination/Substitution”.  But if this is not possible…...

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Compressed Gas Cylinders, OSHA and your AHJ with the IFC

Have you taken the 3 minutes to read OSHA’s expansive Compressed Gas Standard 1910.101?  After all, the standard is three sections long and references Compressed Gas Association (CGA) pamphlets that are no longer in print.  One of the most requested standards I get from SAFTENG members and clients is for CGA P-1 (1965): Safe Handling…...

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A look at back at fire safety

It seems every generation is destined to have its own structure fire tragedy; ours being the Station Nightclub fire in West Warwick, Rhode Island in 2003.  In less than 30 minutes, 100 people lost their lives that night (February 20, 2003).  I had just started consulting and I can remember it well as almost all…...

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