Safety Info Posts

EPA issues RMP citations @ ice manufacturing facility (NH3 & $182K)

Respondent owns and operates an ice manufacturing facility that typically operates 24 hours a day, seven days a week. On June 26, 2019, EPA performed an inspection of the Facility pursuant to Section 112(r) of the CAA, Sections 304-312 of the Emergency Planning and Community Right-to-Know Act (“EPCRA”), and Section 103 of the Comprehensive Environmental…...

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Example of LATENT failures – Auditing

Many organizations have become very good at identifying the ACTIVE failures associated with an accident; however, in almost all of the accident investigations I have been involved with, I find LATENT failures to play a bigger role than active failures.  But that is a really hard pill for most organizations to swallow.  But there is…...

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Butane Railcar(s) stored on a siding in NC found to be a stationary source under RMP

A North Carolina Administrative Law Judge found that railcars on a “siding” are a “stationary source,” as such, if they contain an EHS over the RMP threshold, they fall under EPA’s Risk Management Plan. This is in line with EPA’s recently proposed changes wanting to apply a 48-hour time frame to the term “storage, not…...

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Silent Killer in a Newly Constructed Manhole

OSHA received notification of a construction site fatality on August 5, 2004 – day following the incident Reported that the employee was found at the bottom of a manhole New sewer system under construction – SIC Code 1623                  … Membership Required You must be a member to...

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UN’s GHS Rev.7 presentation

I am sharing this because OSHA is in the process of adopting Rev. 7 for their new HAZCOM standard, and if they do it, it will change the PSM application to some Category 1 Flammable Gases.              … Membership Required You must be a member to access this content.View Membership...

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EPA Region 1 Chemical Warehouses and Distribution Facilities

EPA Region 1 RMP presentation. It has a lot about Ammonia refrigeration and some other EPA rules.   The presentation has a lot of actual pictures of violations.        … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Worker nearly died after co-worker turned on concrete mixer

A worker performing maintenance inside a cement mixer at a concrete manufacturing company narrowly escaped fatal injuries when a co-worker turned the machine on. An OSHA investigation determined that the company’s failure to comply with federal workplace safety standards nearly cost the worker their life. OSHA learned management knew that federal law required the company…...

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EPA issues RMP citations @ frozen poultry storage facility (NH3 & $151K)

The Respondent operates a frozen poultry storage facility adjacent to other businesses, within several hundred feet of residences, and near a hospital. Respondent uses anhydrous ammonia in a refrigeration “process,” as defined by 40 C.F.R. § 68.3, in a system of pipes and vessels at the Facility (the “Process”). On June 5, 2019, EPA inspectors…...

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My take on “Work as imagined” vs. “Work as done”

This single image captures all we need to recognize about “real-world safety.” The straight black line represents “work as imagined”; this means the work done “by the book” every time.  Anyone who believes humans follow all the rules 100% of the time is living in a fantasy land.  We are wired to find the easy,…...

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