This past week I learned that what used to be allowed only under a “special permit” is now part of the regulation for unloading (and loading) HAZMATs. It was very popular during my time as a safety/PSM manager and all my plants applied for and received the DOT Special permit(s) to unload both Railcars and…...
Over the years I have been told time and time again that there are two absolutes in ammonia refrigeration. #1 – we do not have “temporary operational conditions” so we have no need for “temporary operating procedures” and #2 – there is no “process chemistry” in ammonia refrigeration. But it dawned on me this week…...
Last week I mentioned a trade group was planning to implement a standard/guide (not sure how it will be classified) that will suggest that the industry should use respirators that carry a NIOSH 14G approval rather than the more common 23C respirator. Since all of this has been happening I have received numerous e-mails, calls,…...
RMPs must be updated at least once every five years. EPA offers a Checklist for Submitting your Risk Management Plan (RMP). We must fully update your RMP for resubmission sooner than the five-year anniversary date if any of these changes occur:… Membership Required You must be a member to access this content.View Membership LevelsAlready a...
The Ammonia Safety Awareness Program was developed due to the rise of ammonia-related incidents and hazards over the past few years, including the tragedy at Fernie Memorial Arena. Developed in collaboration with industry professionals, this program provides training and downloadable tools to fill in knowledge gaps and share best practices for maintaining ammonia refrigeration equipment and…...
This topic has always been one that seemed to be controversial in the ammonia refrigeration sector, with decades of denial that Stress Corrosion Cracking could occur in an ammonia refrigeration process due to the water content in the ammonia. But last month, Technical BC (British Columbia) discussing their SCC concerns related to pressure vessels in…...
One of the biggest and longest debates in process safety circles is the responsibility of businesses to upgrade their process design(s) based on an updated RAGAGEP. OSHA attempted to address this in a 2016 LOI. Now EPA has stated their “official position”… (emphasis by me)… Membership Required You must be a member to access this...
The Respondent owns and/or operates a chemical manufacturing facility that uses: A. Oleum (fuming sulfuric acid) [sulfuric acid, mixture with sulfur trioxide] (“Oleum”); B. Hydrogen fluoride/hydrofluoric acid (cone 50% or greater) [hydrofluoric acid] (“Hf “). in a fluoroproducts process and a sulfuric acid process. From August 28 – 31, 2018, EPA conducted an inspection of…...
The Facility is a nitrogenous fertilizer manufacturing facility that produces anhydrous ammonia, urea solutions, urea-ammonium nitrate, and by-product gaseous carbon dioxide. The Facility also produces intermediates (including nitric acid and ammonium nitrate solution) during the manufacture of the above products. Based on the quantity of anhydrous ammonia present at the Facility, the Facility is subject…...
OSHA updated a 2017 Letter of Interpretation in January 2021 and it is causing quite a stir in the anhydrous ammonia (NH3) fertilizer industry and could have impacts on other industries that use NH3. In this revised LOI, OSHA states… … Therefore, OSHA believes it is possible, and indeed likely, that any given release of…...
I just finished reviewing a draft document that a trade group will be asked to vote to sanction the document as it relates to emergency escape respirators. There was a lot of talk about requiring these escape respirators to carry the NIOSH approval of 14G (vs. the more traditional 23C style respirator). There is talk…...
At least every five (5) years a Risk Management Plan must be updated. We are seeing a lot of RMP that have been updated in the past 12-16 months that failed to include this in their update. I wrote about this new requirement this past weekend, but now I want to demonstrate the “fall-out” from…...
