Safety Info Posts

Have we updated our EAP and/or ERP to ensure compliance with 40 CFR Part 1604?

Back in February, I broke down the Chemical Safety Board’s new Chemical Incident Reporting Rule (40 CFR Part 1604) and since then we have conducted quite a few safety reviews, emergency response training sessions, and PSM/RMP audits and so far we have not found a single facility that has updated their Emergency Response and/or Emergency…...

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Chlorine Dioxide released inside a tomato processing plant – 47 workers sent to hospital

On August 21, 2011, Forty-seven (47) employees, 38 from the primary employer and nine (9) from a secondary temporary agency, were sent to hospitals for treatment of respiratory irritation after being exposed to chlorine dioxide released inside a tomato processing plant. Three (3) employees were admitted for further treatment. The chlorine dioxide release was due…...

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EPA issues RMP citations @ biopharmaceutical facility (NH3 & $527K)

Respondent owns and operates a biopharmaceutical facility that stores and uses anhydrous ammonia in parts of the storage and refrigeration process. Respondent’s storage and refrigeration process does not meet the eligibility requirements for Program 1 under 40 C.F.R. § 68.10(g) and is subject to the OSHA process safety management standard since the process involves ammonia…...

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EPA issues EPCRA citations @ meat processing facility (1,700 lbs NH3 release & $68K)

Respondent is the owner of the meat processing facility which utilizes anhydrous ammonia, a hazardous substance, at the Facility.  From December 28-30, 2017, Respondent inadvertently released approximately 1,700 pounds of ammonia due to a faulty isolation valve in the Facility’s refrigeration system (“the Release”). On December 13, 2018, EPA conducted an inspection of the Facility…...

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EPA issues RMP citations @ chemical plant (HF, Cl2, HCL, VDF & $17K)

Respondent is the owner and/or operator of the Facility, which has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. On February 26, 2019, the EPA issued to Respondent a Notice of Potential Violation (“NOPV”), providing notice that the EPA found that Respondent…...

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Chlorine (Cl2), the IFC, and treatment system

I have updated my original presentation from many moons ago (2005) for a new Cl2 client using the 2018 Edition of the International Fire Code (IFC) requirements for Storing, Using, Dispensing, and Handling Cl2.  SAFTENG members can log in and download the .ppt file which can be used as-is or it can be modified to…...

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Stop Valves in Pressure Relief Piping (ASME B31.3)

I have written about this topic numerous times, and each time it causes controversy among the SAFTENG members.  Some members are adamant that we should NEVER allow any “intervening valve(s)” in our pressure relief systems; others have seen it done many times.  ASME VIII does indeed allow “intervening valves” before and/or after a Pressure Relieving…...

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Pneumatic pressure testing gone bad (2 fatalities @ food plant)

At 8:30 a.m. on June 22, 2020, Employees #1, 25, and #2, 47, employed by a piping company, were working on the roof of a three-story food processing company. They were adding new pipe to two (2) new, already installed, 14-inch diameter chilled water lines. The chilled water lines had been pressure-tested with nitrogen…. Membership...

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PRCS fatalities (1 Entrant; 1 Would-be-Rescuer) in dredging vessel’s ballast tank (Oxygen Deficiency)

On May 19, 2021, a supervisor entered a dredging vessel’s ballast tank for an inspection. The supervisor entered the tank without any appropriate Personal Protective Equipment (PPE) and did not check if the confined space was safe. Shortly after entering, he collapsed and passed out. After some time, another worker entered the tank in an…...

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Chemical plant fined after major gas leak (chloride-induced stress corrosion)

A petrochemical plant has been fined after ethylene, a flammable gas was released from a cracked pipe at the Ethylene Plant. On May 2, 2017, approximately 17 tons of ethylene were released from the pipe. This leak precipitated the formation of a flammable gas cloud of around 2,295,453 cubic ft. The gas cloud was seen…...

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Improper Grounding Faulted in 2019 Ethanol Tank Explosion

              The report said an abnormal flow of electricity occurred as a result of “improperly grounded equipment” in the roof area of the tank, a static discharge or ignition charge in the tank was the “most probable cause of ignition” in the October 15, 2019 incident.  The tank’s roof…...

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Are you doing an annual audit on your Respiratory Protection Program (1910.134(l))

Many of us manage a Respiratory Protection Program for all types of respirators and many types of hazards.  What many programs lack is the annual evaluation of the program and its execution. The written program should contain information on how and who will perform this evaluation and although the standard does not state this evaluation…...

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