Hazardous Materials

Spills onto concrete floors inside a building (EPCRA reporting)

A facility has a spill of an extremely hazardous substance in an amount greater than its reportable quantity.  The spill occurs on a concrete floor that is inside a facility building.  Before the spill can be cleaned up, a portion (less than RQ) of the EHS enters the outside atmosphere through the window.  Persons in…...

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Who must be notified of a release under Emergency Planning and Community Right-to-Know Act (EPCRA)?

The notice required by section 304 of EPCRA is to be given by the owner or operator of a facility (by telephone, radio, or in person) immediately after the release of a CERCLA hazardous substance or of an EHS at or above the RQ. Notice is to be given to:… Membership Required You must be...

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Can trucker drivers stay in their cab during the unloading of a flammable liquid?

We often get this question during audits and PHAs, as it seems to be “common practice” for the driver to reside inside their cab doing paperwork while they are the intended “hazmat attendant”. And although it may not be perfectly clear under DOT regulations (I think it is clear there as well, but many will…...

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Are hazardous chemicals present at rail yards subject to EPCRA 311/312?

Yes, hazardous chemicals present at rail yards are subject to EPCRA Sections 311 and 312, if they are NOT stored incident to transportation and they are present at the rail yard in amounts equal to or in excess of the minimum thresholds in 40 CFR 370.10(a). As explained in the answer to the question “are…...

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What is the definition of “off-site property damage?” (EPA RMP FAQ)

I am working on the five-year accident history portion of the hazard assessment under the RMP.  Section 68.42(a) tells me to include “all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.”  Is there…...

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Accidental releases from non-covered processes (EPA RMP FAQ)

Should the owner or operator include accidental releases from processes containing listed substances below the threshold quantity in the five-year accident history required under the hazard assessment provisions of 40 CFR Part 68, Subpart B, and in the incident investigation requirements under 40 CFR Part 68, Subparts C and D? No…. Membership Required You must...

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Pipefitter Struck in Chest While RemovingEnd Cap from Pressurized Pipe

In December 2006, a journeyman pipefitter (P1) was struck in the chest by a pipe cap that he was removing from a pressurized pipe. Some leaks in an 8-inch waterline needed repair. To help find the leak locations, valves were closed off in the lines, creating sectionalized portions of the air-charged waterline. The waterline was…...

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The energy of compressed gases

Gas cylinders holding 1.5 ft3 of gas are often filled to ~2,100 psig. At such high pressure, damaged or mishandled cylinders can fracture violently and release enormous amounts of energy, comparable to…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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LPG Cylinders for PITs require a 12-year requalification – MANY do NOT get them

I have seen a cost savings trend that is increasing risks in a big way. It may seem minor to those who do not understand risk, but using a pressure cylinder without it being inspected and tested at its prescribed frequency is a serious safety miss. Usually, these risks are controlled somewhat when the facility…...

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UPDATE: Massive Container Explosion Was Caused By Self-Heating Chemical Cargo (Runaway Reaction of tert-butyl perbenzoate (TBPB)

According to China’s Maritime Safety Administration (CMSA), the shipping container explosion aboard the box ship YM Mobility at Ningbo in 2024 was caused by thermal runaway in a cargo of organic peroxides. The container in question was a refrigerated shipping container filled with tert-butyl perbenzoate (TBPB), a common activator for making plastics like polyethylene and polyester. It…...

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Overfilling LPG Cylinders

Recently, I shared the investigation results of the fatal LPG explosion in Hillsboro, OH. The cylinder had been overfilled, leading to its catastrophic failure, which then led to LPG gas finding an ignition source in the car repair garage and exploding. I took some flak for stating that I have seen overfilling of LPG cylinders…...

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