Hazardous Materials

The OSHA HAZWOPER requirement 99% of Industrial facilities fail to meet

There is one requirement in the HAZWOPER standard that has been in place since its promulgation, which almost every industrial facility with its own internal HAZMAT response team fails to meet. I receive a significant amount of pushback when I cover this OSHA minimum requirement, and I am always as shocked by the response as […]

OSHA’s current interpretation of the HAZWOPER standard as it relates to IDLH operations

Here is OSHA’s current interpretation of the HAZWOPER standard as it relates to IDLH operations. The LOI specifically addresses the HAZWOPER requirement for workers who are engaged in remedial operations as well as in emergency response operations in atmospheres that are or may be IDLH AND who utilize self-contained breathing apparatus (SCBA) for the control

350 pound NH3 release @ potatoe processing plant leads to $65K in EPCRA citations

Respondent produced, used, or stored ammonia at the Facility and released a reportable quantity of an EHS, ammonia. On or about August 31, 2022, a “release” of ammonia in excess of 100 pounds occurred at the Facility (the release). As a result of the information obtained by the EPA and subsequent investigation, the Complainant has

Bypassed Safety Device Deficiencies (BSEE)

A team of auditors identified a potential risk associated with bypassed safety devices and inconsistent interpretation of regulations after multiple incidents of noncompliance were issued, associated with the operator’s failure to comply with 30 CFR 250.869 and 30 CFR 250.870 in 2025. The BSEE Performance-Based Risk Inspection (PBRI) covered five assets (all production platforms) in

Fatigue Cracking of ¾-Inch Pipe Nipple Results in Gas Release (BSEE)

The Bureau of Safety and Environmental Enforcement (BSEE) has investigated a recent offshore gas release incident resulting from the failure of a ¾-inch pipe nipple connected to a compressor suction scrubber (Figure 1). The failure led to an immediateplatform shut-in and a full muster of personnel onboard. The released gas posed a significant safety risk,

Consider Human Error and Domino Effects (EPSC Learning Sheet July 2025)

At an Ethylene unit in the Czech Republic (2015), when swapping over cooling water supply lines during a flowmeter calibration, the operator made a simple mistake. While intending to open valve #3 on the spare supply line, he closed the identical valve #2 instead, shutting off all cooling water to the Light Ends columns. A

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