Having had the privilege of working with a railroad this year, I have learned a lot about how “safety” functions in an industry sector I knew absolutely nothing about. But in this time, I have come to really like the Federal Railroad Administration’s (FRA) approach to managing safety across this industry. The FRA had to…...
Today I got one of my favorite magazines, of which I have been suggesting everyone in the PSM arena subscribe to (for FREE) – The BULLETIN from the National Board. And in this edition, the NB has an article on the Hanson RV that has an indicator telling when the valve has been activated. These…...
Respondent operates a petrochemical manufacturing process at the Facility, utilizing regulated substances to produce vinyl chloride monomer, meeting the definition of ” process”, as defined by 40 C.F.R. § 68.3. Sulfur dioxide, hydrogen chloride, vinyl chloride and propylene (collectively, “regulated substances”) are each a “regulated substance” pursuant to 40 C.F.R. § 68.3. EPA conducted an…...
Respondent is the owner and/or operator of a Brewery and has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. At its Facility: Respondent operates an ammonia refrigeration plant. Respondent has on-site for use, 160,300 pounds of anhydrous ammonia. Respondent has one RMProgram…...
WTH? Did Haywood just say that? Yep – I am afraid I did and I mean it. Now my personal actions do not reflect that belief, as I am a safety professional and I want every decision you make to be one based on YOUR SAFETY. But as a business, safety can never be #1! …...
Buzz words… oh how I have come to hate them. In my earlier days in this profession, it was called “flavor of the month safety” as we had some catchphrase or “program” we’d implement to try and break through the “mental fog” that caused workers to work unsafely. Then came along the “silver bullet of…...
We do a lot of work in flammable atmospheres so yes we have rather high standards for what “minimal compliance” looks like. We recently came across this situation while performing an assessment for a facility that has suffered from a flash fire months earlier. During our walk-thru of the area (they knew we were coming)…...
Both 1910.178 and 1910.147 have requirements that we periodically evaluate employees’ performance in their ability to perform LOTO and drive PITs in the manner in which they were trained. As I have discussed many times, just doing annual LOTO training without some type of “field verification” that the authorized employees are functioning within the program’s…...
First, let me say this article was written for those who do NOT live in the world of process safety, but yet they do have hazardous materials on-site in some type of bulk system, albeit below the PSM/RMP thresholds. In this posting, I am going to use Propane/LPG as my HAZMAT as there are many…...
The Ohio Environmental Protection Agency, Division of Air Pollution Control (DAPC) has adopted amended rules in Ohio Administrative Code (OAC) Chapter 3745-104, “Accidental Releases Prevention Program” Rules. The rules in this chapter establish Ohio’s Accidental Release Prevention Program. These rules were promulgated after Ohio received the delegation of authority from USEPA in December 1999 for…...
Respondent owned and operated a petroleum refinery with the Standard Industrial Classification (SIC) code 2911. The Facility produces, processes, stores, or handles more than the threshold quantities of flammable and toxic substances identified in 40 C.F.R. § 68.130. The regulated flammable substances that are held above the threshold quantities identified in 40 C.F.R. § 68.130…...
Respondent is the owner and operator of a facility that has five inorganic chemical manufacturing processes, meeting the definition of “process”, as defined by 40 C.F.R. § 68.3. Bromine, ammonia (anhydrous), chlorine, sulfur trioxide, propylene oxide, oleum (fuming sulfuric acid), and sulfur dioxide (anhydrous) are each a “regulated substance” pursuant to 40 C.F.R. § 68.3…....
