Safety Info Posts

How many worst-case release scenarios must be analyzed and documented in the RMP?

As a part of the hazard assessment requirements in 40 CFR Part 68, Subpart B, I must analyze worst-case release scenarios and document certain analyses in my risk management plan (RMP). How many worst-case release scenarios must be analyzed, and how many analyses must be specifically documented in the RMP?… Membership Required You must be...

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Differences between EPA’s RMP and EPCRA

How do the Clean Air Act (CAA) risk management program requirements differ from the hazardous chemical reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA)?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Safety banners do not talk, but more importantly, they do not have the ability to LISTEN either

Recently, I had the pleasure of touring the flagship facility of one of my original supporters of SAFTENG. The safety pro is a world-class leader and a fine safety engineer. When he arrived at this facility, he and the PM decided to rid the workplace of all the “safety banners.” Most had become eye-sores, some…...

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Questions & Answers for OSHA’s Update to the HCS Final Rule

Which establishments are covered by the update to the HCS? The scope and framework of the HCS have not changed with this rulemaking. Chemical manufacturers and importers are still responsible for providing information about the hazards of chemicals they produce or import. All employers with hazardous chemicals in their workplaces continue to be required to…...

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OSHA Recordkeeping Updates

#1 If an employee presents a work status that indicates they are able to perform restricted work or light duty work yet we do not have work available that meets the restrictions, should we enter the number of days under “On Job Transfer or Restriction” or “Away from Work?”… Membership Required You must be a...

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EPA RMP GDC & EPCRA citations @ facility that produces glass-to-metal seals and high-temperature co-fired ceramics (NH3 & $117K)

Respondent operates a facility that produces glass-to-metal seals and high-temperature co-fired ceramics for use in semiconductor products. The Facility is located just over half a mile from a residential neighborhood; just under three-quarters of a mile from a charter school; just over three-quarters of a mile from a church and a skating rink; less than…...

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Defending H.W. Heinrich – The Accident Pyramid

I am just getting into Carsten Busch’s book The Heinrich Project III and it has already made it onto my top 10 list for safety pros. Carsten put together all of H.W. Heinrich’s articles and speeches from when he was with Traveler’s Insurance. If you are a believer, as I am, in many of the…...

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QUESTIONS AND ISSUES COMPILED FROM THE EMERGENCY RESPONSE NOTICE OF PROPOSED RULEMAKING

There has been a lot of public debate about OSHA’s attempt to update its emergency response standards.  And in this debate there has been a lot of misinformation shared across municipal and private fire brigade groups in what OSHA is actually trying to implement.  This document, from OSHA, is a compilation of the questions posed…...

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EPA RMP & GDC citations @ facility manufacturing chlorine, bleach, and hydrochloric acid ($85K w/ two SEPs @ $264K & $98K)

Respondent operates a facility to manufacture chlorine, bleach, and hydrochloric acid. At all times relevant to this CAFO, Respondent produced, used, or stored more than 2,500 pounds of chlorine at the Facility and was subject to the requirements of CAA § 112(r)(7). At all times relevant to this CAFO, Respondent produced, used, or stored hydrogen…...

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What a delight to hear a CEO and COB talk about safety in the right way

Recently, I had the pleasure of working with one of my international clients at several locations.  This is in thanks to Paul A. for putting his trust in me throughout my career.  Paul and I met in Omaha, NE, in the late 90s and formed a professional and personal friendship as he is ALL ABOUT…...

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Railcar Loading and Unloading operations (Canada)

Much of my work involves helping clients achieve more than “compliance” with minimum government standards.  I typically do this using RAGAGEPs; however, those may be too much to handle in some situations.  So, I will propose another government standard that applies to the process/hazard.  For example, unloading flammable liquid railcars.  Canada has some of the…...

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May be a bit out of spec for API 570

This is safety satire on a Friday afternoon after a long week! I may not be a Certified Welding Inspector (CWI) or a Visual Level II inspector certified per ASME V Supplemental NDE Certification requirements. Still, I believe API 570, Section 8 Repairs, Alterations, and Rerating of Piping Systems allows only a dozen or fewer…...

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