Safety Info Posts

EPA issues RMP citations @ refinery (Flammable/Toxics & $385K)

Respondent is the owner and operator of an oil refinery. On September 9-13, 2019, the EPA inspected the Facility to determine compliance with 40 C.F.R. part 68. Based on the observations of the EPA inspectors at the inspection, the EPA has determined that Respondent uses, handles, and/or stores more than the threshold quantity of Flammable…...

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LOTO Periodic Inspections, HOP, and Psychological Safety

First, I am not fully bought into the “psychological safety” concept.  For me, it is just how we should manage safety, so I am not a “labels” kind of safety pro.  However, I get a lot of questions about HOP and Psychological Safety, and the one place we could begin to utilize these approaches is…...

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2024 safety resolutions… Written Program Specifics

On New Year’s Eve, I hope many safety pros will choose a 2024 resolution to end the regurgitation of OSHA standards as their “written programs.” I have always used the OSHA standard as my baseline, but these programs need to EXPLAIN HOW the facility will meet the requirements – not repeat the requirements. For example……...

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Safety Tip… its not the air that is the hazardous energy source; its what the air moves that creates the hazard

One thing that many find confusing regarding the control of hazardous energy is the actual hazard they are trying to render to a Zero Energy State (ZES).  This is a simple concept, but many get it wrong in their programs and machine-specific procedures.  Let’s take compressed air as an example.  Many compressed air systems in…...

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Fire extinguisher fails during pressure testing

What happened? The extinguisher, rated to 2900 psi was being tested to a pressure of 4351 psi. The incident occurred when the test pressure reached 2842 psi. The extinguisher was 13 years old. No one was harmed. The failure occurred under test conditions, and no personnel were nearby to be injured. The hydrostatic test was…...

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Equipment Opening gone bad (barium sulfide wash cone with a steam line)

NOTE: this was NOT a PSM covered process. OSHA determined the employee — on the job just two months — opened an air intake valve to inspect a noise coming from a barium sulfide wash cone with a steam line that was left open the day before. A rush of cold air in the steam…...

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Periodic Inspections should be SIMPLE and straightforward

Lockout is a life-critical program/process/procedure(s). Our efforts to VERIFY that the program/process/procedures meet our needs is a CRITICAL path in the LOTO process.  OSHA recognized this when it promulgated its Control of Hazardous Energy standard (1910.147).  Specifically, 1910.147(c)(6) “Periodic Inspections” requires the employer to verify the program/procedures and that the employees can properly apply them…...

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What does it mean when our facaility is a “High-hazard Group H occupancy”

High-hazard Group H occupancies are characterized by an unusually high degree of explosion, fire, or health hazard compared to typical commercial and industrial uses.  There is one common feature about Group H occupancies—they are designated as Group H based on excessive quantities of hazardous materials within the facility/building. Where the quantities of hazardous material stored…...

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Safety and Seperation Distances

From “facility siting” in a PHA to establishing emergency “assemble areas,” the methodology we use matters.  Many of us use a RAGAGEP from The European Industrial Gases Association (EIGA) titled Methodology for Determination of Safety and Separation Distances.  The “safety distance” is to provide a minimum separation that will mitigate the effect of any foreseeable…...

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CSB Releases Final Report into 2021 Fatal Vapor Explosion and Fire at Yenkin-Majestic Facility in Columbus, OH

Today the U.S. Chemical Safety and Hazard Investigation Board (CSB) released its final report on a flammable vapor explosion and fire at the Yenkin-Majestic facility in Columbus, OH, on April 8, 2021. One employee died during the incident, and eight other workers were injured. The CSB’s final report makes several important safety recommendations to Yenkin-Majestics,…...

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