Respondent has an Ethanolamines unit used for chemical manufacturing purposes at the Facility that has greater than a threshold quantity of anhydrous ammonia. EPA Findings of Violation Count 1 – Quality Assurance
At 9:00 a.m. on January 31, 2022, an employee who worked as a General Laborer fo r an Industrial Nursery was filling propane cylinders from a bulk propane tank. As the employee was finishing filling a cylinder, he began to remove the filling hose before shutting off the propane. As a result, the gas escaped
Investigations of accidents in a number of hazardous domains suggest that a cluster of organizational pathologies—the “vulnerable system syndrome” (VSS)—render some systems more liable to adverse events. This syndrome has three (3) interacting and self-perpetuating elements: Blaming front-line individuals, Denying the existence of systemic error provoking weaknesses and Blinkered pursuit of productive and financial indicators
productThis week I have been helping a client/friend understand what a true non-entry rescue system looks like and how it functions. Back in July 2011, I wrote an article titled “CS Rescue… Tripods and Winches and a false sense of security” to help facilities understand the vast limitations of the traditional tripod and winch setup.
The respondent operates a water chlorination process. On July 27, 2021, EPA conducted an announced inspection of the Facility. The Facility maintains a maximum inventory of 14,000 pounds of chlorine, a regulated substance, as a liquified compressed gas in 1-ton cylinders. Here are the findings from the inspection:
I found another ppt from years ago, dusted it off, and updated it for a client. This is based on many of the HOP/HPI/Resiliency talks we hear these days. But know this, without trust, NOTHING will work in our effort to improve the worker’s safety. My favorite saying on trust is from Dr. Clive Lloyd:
After the month I have witnessed, this image came to me this weekend as I reflected on the state of safety in the USA. I have mentioned before, has the compliance model done more harm than good? I mean, OSHA has made a huge impact on workplace safety. Still, once a business achieves “compliance” (and
Light hydrocarbon was released through a pinhole breach of an insulated process pipe. A plant operator detected an abnormal hydrocarbon odor and immediately responded as per site emergency protocol. A localized possible breach was identified, and the processing unit was safely shut down for further investigation. A 3-inch insulated pipe connecting process piping to
If you have not yet read Clive Lloyd’s “Compliance to Care”, it is a must-read. Here are my five (5) favorite points he makes:
I enjoy the engineering side of safety more than the cultural piece, but both play a critical role in achieving world-class performance. After spending 18 years consulting and do more technical consulting than cultural, it has been fun working with a single client on culture this year. It allowed me to dust off a lot
The systems approach provides a framework for the analysis of errors and efforts to improve safety. Many specific techniques can be used to analyze errors, including retrospective methods such as root cause analysis and prospective methods such as failure modes effect analysis. Failure modes effect analysis (FMEA) attempts to prospectively identify error-prone situations, or failure
Respondent operates a food manufacturing process involving ammonia refrigeration with more than 10,000 pounds of anhydrous ammonia on site. Respondent has an RMProgram level 3 covered process, which stores or otherwise uses anhydrous ammonia in an amount exceeding its applicable threshold of 10,000 pounds. On February 27, 2020, the EPA conducted an on-site inspection of
