Safety Info Posts

Vietnam suffers another industrial mass casualty event (Boiler Explosion kills 6)

Six people were confirmed dead in a boiler explosion at a wood factory in the southern province of Dong Nai on May 1, 2024.  The accident also injured five others. The provincial People’s Committee has offered condolences and financial support to the victims’ families (20 million VND or 789 USD for each fatality and 10…...

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The simple path to implementing SIF

In the world of industrial safety, we are not at a loss for the desire to try new things. Many consulting companies are waiting to sell us their shiny gadgets. One of these latest crazes is called “SIF”—Serious Injuries and Fatalities. The concept behind this model is based on the progress many have made in…...

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Tank used to store ammonia to be used as both agricultural fertilizer and coolant

Ammonia is held for sale by a retailer in a large storage tank.  The retailer sells ammonia as an agricultural fertilizer and a coolant for air conditioning systems.   Section 311(e)(5) of EPCRA exempts from the definition of a hazardous chemical “(a)ny substance to the extent it is used in routine agricultural operations or is…...

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CFAT Impacts on EPCRA and RMP

The Department of Homeland Security’s Chemical Facility Anti-Terrorism Standards (CFATS) impose comprehensive federal security regulations for high-risk chemical facilities. Do the CFATS alter the requirements that apply to a facility covered under both CFATS and either the Emergency Planning and Community Right-to-Know Act (EPCRA) or the Clean Air Act §112(r) (i.e., the Risk Management Program…...

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U.S. EPA updates list of states granted delegation of EPA’s authority to implement and enforce the risk management program rule?

The current list of delegated states and counties is: NOTE: Kentucky, Puerto Rico, and the Virgin Islands no longer implement the program, and the regional office has taken over the implementation of those areas…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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U.S. EPA updates list of states granted delegation of EPA’s authority to implement and enforce the risk management program rule? Read More »

OSHA breaks down some key parts of its LOTO standard

These requirements control the release of hazardous energy while workers service, maintain, or repair machines or equipment when activation, start-up, or release of energy from an energy source is possible; proper control of hazardous energy prevents death or serious injury among these workers. Energy Control Procedure (paragraph (c)(4)(i))… Membership Required You must be a member...

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CO2 Dewar catastrophically fails at Orlando restaurant

UPDATED on 6/6/24 with OFD Run Report and Investigation   I have written about the risks associated with wanting to use larger CO2 containers in the restaurant industry. The IFC now has a section on the hazards associated with these larger cylinders. Still, most of the code deals with CO2 leaks causing an oxygen-deficient atmosphere,…...

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Just what is required for a High-hazard Group H occupancy?

High-hazard Group H occupancy includes, among other things, the use of a building or structure, or a portion thereof, that involves the manufacturing, processing, generation, or storage of materials that constitute a physical or health hazard. Hazardous occupancies are classified in Groups H-1, H-2, H-3, H-4 and H-5. High-hazard Group H-1 buildings and structures that…...

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How an MOC can avoid reacordable injuries/illnesses

Much like it is in process safety, the Management of Change (MOC) tool may be the most despised element of an SMS.  However, a recent safety assessment with a local client identified the lack of performing an MOC on significant changes to production machinery and rates.  The facility is NOT a PSM facility, but they…...

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Inspections vs Audits

The words “audits” and “inspections” often get used as if they are the same thing – THEY ARE NOT the same.  I always like to say we inspect “things,” and we audit those inspections. Much like my previous post earlier this month, explaining the difference between “examinations” and “inspections” as used in ASME B31 series;…...

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SMS Auditing: 1st Party, 2nd Party, 3rd Party

One of the more critical elements of an SMS is “auditing.”  In the Plan-Do-Check-Act model, auditing falls within the “CHECK” function.  I like to say it’s the element that keeps us honest and informed.  And with that in mind, I break down my audits into three (3) layers: → 1st Party → 2nd Party →…...

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Old secondary containment design vs. New secondary containment design

In the old days, the secondary containment around flammable liquid storage tanks could be a single system in which all the storage tanks sat. Today, that is NOT the case. Both NPFA 30 and IFC Chapter 57 require the secondary containment to be such that an LOPC from one tank can NOT impact the other…...

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