Safety Info Posts

Elemental Chlorine (Cl2) is NOT present in sodium hypochlorite (NaOCl)

Whenever I am doing a Chlorine project this always comes up, as I almost always try and get anyone who is using elemental chlorine to make the switch to “bleach”, or sodium hypochlorite (NaOCl).  Too many facilities are not capable of safely storing and handling elemental chlorine – that is just a hard fact.  These…...

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Does your LOTO training include some basic ESRWP training?

In a lot of older plants, personnel who are locking out equipment are not granted the convenience of a “local electrical disconnect,” meaning they have to use what I call “knife disconnects” such as this: Or do we make the qualified electrical workers the “gatekeepers” of all electrical LOTO, and thus only they operate these…...

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OSHRC vacates HAZWOPER citation for response to NH3 @ a power plant

This case has bounced around for a while now, but the power plant won their case and had the 29 C.F.R. § 1910.120(q)(3)(iv) citation vacated by the OSHRC.  On a personal note, I agree with the dissenting opinion.   Only Item 2 of that citation is at issue on review—it alleges a violation of 29 C.F.R…....

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DOJ puts Ice Plant (NH3 refrigeration) on notice for failing to implement an RMP

You have to be really special to get EPA’s Criminal Investigation Division involved in your RMP inspection – DONT BE SPECIAL! But once again we have a NH3 refrigeration facility just not “getting it”… The case was prosecuted by Assistant U.S. Attorney Terrence P. Donnelly, with the assistance of Dianne Chabot, EPA Regional Criminal Enforcement…...

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What do you think the most are the most hazardous chemicals on our streets/rails/water-ways and air were in 2015-2018?

PHMSA identifies the hazardous materials that have been linked to the most serious consequences in terms of deaths and major injuries relative to exposure. The Office of Hazardous Materials Safety (OHMS) periodically reviews the incident data to explore, develop and refine methodologies that illustrate which hazardous materials are most likely to be involved in death…...

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Air-Conditioning, Heating and Refrigeration Institute (AHRI) fire safety study on A2L Refrigerants

The phase-down and restriction of the most common and widely used refrigerants was initiated in the late 1980’s and has spurred innovation, both for the alternative refrigerants that have been introduced as well as in the equipment that uses them. Safety Group A2L refrigerants (lower toxicity and lower flammability) represent the most recent in the…...

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NH3 Line break from hell!

I will give these guys this credit… they make great videos for the ammonia refrigeration industry.  But as a safety professional, I was appalled at some of their actions and lack of safety while watching two of their videos.  This particular video shows two (2) workers removing and replacing an NH3 valve – a clear…...

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LNG by rail is coming to your hometown

After nearly 20 years in ER specializing in large-scale incidents, I can say that with this news I am sorry I got out of the work when I did.  This addition to the rails of the USA will be a fun and wild addition.  LNG—referred to as “Methane, refrigerated liquid”  within the HMR—has been transported…...

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Issues with allowing SCBA cylinders past their hydrostatic testing due date to remain in-service

I see this practice, keeping cylinders in-service beyond their hydro due dates, and I just want to make everyone aware that although this practice may be complaint with 49 CFR Part 180, it sets up the Emergency Response Team (ERT) with a potentially serious Breathing Air (BA) issue during a response.  There are two failures,…...

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Are your 1-ton chlorine cylinder trunnions in your MI program?

This week I shared a serious chlorine incident that sent seven (7) people to the hospital, including firefighters and neighbors.  This incident could have been managed very easily and with much fewer impacts on responders and the community had the facility followed basic RAGAGEP requirements for their 1-ton chlorine containers.  Basically, the leak was on…...

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Is a Chlorine 1-ton cylinder a DOT container requiring hydrostatic testing?

We have discussed hydrostatic testing of all sorts of containers, most notably our SCBA cylinders and our process piping.  But one very important cylinder I do not mention near enough is the 1-ton Chlorine cylinders.  All chlorine cylinders, except DOT 3E 1800, MUST BE HYDROSTATICALLY TESTED EVERY FIVE-YEARS from the date of the previous hydro…...

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