Safety Info Posts

CFATS by the numbers on its 15th Anniversary

November 20, 2022 was the anniversary of Chemical Facility Anti-Terrorism Standards (CFATS) regulations.  And although it is not as well known as OSHA’s PSM and EPA’s RMP standards, it is a standard that many PSM/RMP practitioners deal with, so I thought it would be fitting to look at the CFATS numbers…… Membership Required You must...

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EPA offers insights into “Responding Facility” vs. “Non-Responding Facility”

In a recent training course, the EPA answered the “One Big Question”… (one that I have written about many times) Does the facility rely on emergency responders to stop the release of the regulated substance(s)? If the facility answers Yes, they are saying the local first responders will respond and stop the release.  This means…...

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Fish holds on commercial fishing vessels (H2S)

This Safety Alert addresses the importance of verifying atmospheric conditions in fish holds on commercial fishing vessels. There are specific hazards associated with the use of brine dip solutions, a common substance used in the industry. Brine dip combined with standing water can produce dangerous levels of hydrogen sulfide (H2S). The U.S. Coast Guard is…...

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EPA RMP Citations @ olefins facility (Flammables & $9K w/ $43K SEP)

Respondent is the owner and operator of an olefins facility which had two (2) incidents that occurred on December 20, 2021, and May 3, 2022, that resulted in accidental releases. Respondent has an olefins unit process at the Facility, meeting the definition of ” process”, as defined by 40 C.F.R. ยง 68.3. EPA Findings of…...

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Active vs. Latent Failures

A comparison of the characteristics of active and latent failures suggests that avoiding active failures tends to drive down the frequency of events while finding and rectifying the results of latent failures tends to drive down the severity of events…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

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A lot of OSHA standards follow the SMS protocol

Whether we recognize it or not, many of the OSHA standards follow the principles of a well-grounded Safety Management System (SMS) that includes: Hazard Identification Hazard Analysis using a recognized methodology Risk Assessment so that risk can be quantified and put into perspective Risk Mitigation using the Hierarchy of Controls (Elm, Sub, Eng, Adm, PPE)…...

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So many first steps in OSH turn out to be trips and falls

In occupational safety and health, there are a lot of opportunities for businesses to stumble and fall right out of the gate. Although many folks like to claim “anyone can do safety,” this myth drives these mistakes. Untrained/Uneducated persons are attempting to manage an OSH program and stumbling at step one, leaving hundreds/thousands of employees…...

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The 2021 IMC catches up to the large-diameter ceiling fans

Most of us have seen these “Big _ss” fans before.  They move a lot of air and work well. (This is not an endorsement of the brand).  Now, the 2021 International Mechanical Code (IMC) has caught up with these types of large-diameter ceiling fans. These fans are DEFINED and QUANTIFIED as: A ceiling fan that…...

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Electric sweet gas heater ruptures and releases sweet gas into the building

This incident was process related and involved a process safety system; however, the process was NOT PSM/RMP covered.  The incident is process-related and many of the PSM/RMP management elements could have prevented this incident. An electric sweet gas heater ruptured from overheating releasing sweet gas into the building. The cause of the incident was likely…...

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Safety Classification and Learning (SCL) Model

The rate of recordable injuries in the electric power sector has declined steadily over the past decade; however, the rate of serious injuries and fatalities (SIFs) has plateaued. Unfortunately, studying SIFs is a paradox. On one hand, SIFs are incredibly important and deserve significant resources for investigation. On the other, learning from these events and…...

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