SAFTENG audits are known to be “detailed” (the nice way to say it). We believe that when we are working with MINIMUM PERFORMANCE STANDARDS such as OSHA standards and those standards adopted by a facility to support compliance with these minimum standards, all the details matter. One of the most deficiencies we come across involves…...
I get about a dozen calls a year from folks asking me about their PSM/RMP due dates. I try to explain that of course OSHA or EPA can cite the facility if the audit is past due. For example, the last audit was done the 2nd week of February 2020, it is expected that the…...
Respondent has a crude fractionation process at the Facility. EPA inspected the Facility on February 14 – 17, 2022, to determine the Respondent’s compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Butane, isopentane, ethane, propane, and pentane are “regulated substances” pursuant to 40 C.F.R. § 68.3. The threshold quantity for butane,…...
Respondent manufactures a range of specialty surfactants for use predominantly in the oil and gas industry. The process of ethoxylation involves reacting ethylene oxide with various common chemicals, such as fatty alcohols and phenols, to produce a variety of products. The plant can also use propylene oxide instead of (or as well as) ethylene oxide…...
This is from an EPA Multimedia inspection that looked at a chemical process that was below the TQ, so they used the RMP GDC to inspect. What they found in the flammable process was that… … several of the facility’s components were made of aluminum. One condenser was installed with malleable iron tubes instead of…...
Three (3) fundamentals are behind the “electrical classification” model for hazardous locations. These three fundamentals mirror our approach to other workplace hazards, and understanding these three fundamentals will help make a lot of sense out of NFPA 497/499 and 1910.307…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...
The US still uses the Class and Division system to classify electrical systems in hazardous locations. However, outside the US, the Zone system is more widely used. Manufacturers are beginning to list their equipment based on the Zone(s) it is rated for, which can cause translation confusion. The table below may be of help…. Membership...
We can learn a lot from Aviation Safety! I came across this 2017 presentation on Runway Safety Trends and Runway Incursion Analysis and just loved how they analyzed their data to identify the trends, causes, and contributing factors. Some of the data may be alarming, but that is not my intent. This is how we…...
I have spent much time reading NTSB accident reports over my career. They are usually very educational, even for those of us outside the aviation industry. This incident involving this mother of three being sucked into a jet engine has captured a lot of headlines due to its graphic nature, but there will be so…...
I have several clients who offload ships/containers in this manner. Whenever I see this, I immediately go to “that is a PRCS”. The ship/container is for sure a CS, and the fact that we have an engine putting off CO inside the ship/container makes the space a PRCS. I am fortunate enough to have great…...
Yesterday, OSHA announced its plans to promulgate a revised Process Safety Management (PSM) standard and a NEW Emergency Response Standard in 2023. Executive Order 12866 requires the semiannual publication of an agenda of regulations listing all the regulations the Department of Labor expects to have under active consideration for promulgation, proposal, or review during the…...
The OSHRC has vacated four (4) heat-related OSHA citations against the United States Post Office. This decision was based ON LEGAL matters regarding the Feasibility of Abatement of the Hazard. ALL parties agreed to the fact that HEAT CAN BE A HAZARD, but when OSHA issues a GDC Citation, it must provide feasible abatement measures. …...
