Safety Info Posts

2021 International Fire Code (IFC) is now available

The 2021 International Fire Code (IFC) contains regulations to safeguard life and property from fires and explosion hazards. Topics include general precautions, emergency planning, and preparedness, fire department access and water supplies, automatic sprinkler systems, fire alarm systems, special hazards, and the storage and use of hazardous materials. Key changes to the 2021 IFC include:…...

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The Chlorine Institute recognizes three (3) piping pressure testing techniques

All new or modified chlorine piping systems must undergo pressure testing to verify the integrity of the piping (see section 11.4 for leak testing). ASME B31.3 (13.2.8 ), Process Piping testing requirements, should be applied as a minimum standard. There are three (3) types of acceptable testing methods: hydrostatic testing, pneumatic testing, and the alternate…...

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The Chlorine Institute has revised its hydraulic thermal expansion design considerations

Liquid chlorine has a very high coefficient of thermal expansion. Relatively small increases in liquid chlorine temperature can create enough pressure to cause a blocked-in section of piping to rupture or leak at the connections. A temperature rise from 14°F (-10°C) to 32°F (0°C), will expand liquid chlorine by 2%. However, in a contained volume,…...

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The Chlorine Institute revises its piping leak testing protocols

Leak testing should be done once the piping system is completely assembled. The purpose of a leak test is to ensure all connections and components will not leak chlorine when pressurized. Leak testing is not a substitute for pressure testing. If the system was not disassembled and reassembled as part of the pressure testing and…...

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The Chlorine Institute has revised its piping RAGAGEP

The Chlorine Institute has revised its piping RAGAGEP and it is FREE for anyone who wants it.   Pamphlet 6 – Piping Systems for Dry Chlorine, Edition 17 contains major revisions to the following sections, in addition to minor clarifying changes throughout the pamphlet:… Membership Required You must be a member to access this content.View Membership...

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PHMSA issues DRAFT FAQ for Midstream facilities and OSHA’s PSM

PHMSA provides written clarification regarding the pipeline safety regulations found at 49 CFR parts 190–199 in the form of FAQs and other guidance materials. PHMSA is requesting public comment on a set of DRAFT FAQs that were developed by the Working Group that was established by the Gas Pipeline Advisory Committee (GPAC) and the Technical…...

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Is a spiral freezer a Permit-Required Confined Space (PRCS)?

The short and simple answer is YES. It is, without a doubt, a PRCS.  This debate is much like the “Is an Evaporative Condenser a PRCS” discussion.  This week, I was presenting at the 2020 Refrigerating Engineers & Technicians Association (RETA) virtual conference, and my presentation was “Evaluating Your Ammonia Refrigeration System to determine if…...

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EPA RMP citations @ Nitrogen manufacturer (NH3 and NH4NO3 & $1.5M after 2 NH3 releases)

EPA has reached an agreement with a Nitrogen manufacturer to resolve federal civil environmental violations of the Clean Air Act’s chemical accident prevention measures and of federal laws requiring timely notification of chemical accidents. EPA identified these violations following an anhydrous ammonia release that led to thirteen workers being injured at the facility in Arizona…....

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The Eleventh Circuit reinstates OSHA’s LOTO Citation regarding a contractor death

This is SIGNIFICANT for those who truly believe in the purpose and function of OSHA’s LOTO standard.  I was never more disappointed in an ALJ than after they decided to vacate such a clear violation of LOTO.  I may have even said, “Why do lawyers/judges make for bad safety professionals.”  This fatality involved an apprentice…...

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Tenth Circuit Appeals court rules a boiler connected to a PSM/RMP covered process is part of the “covered process”

After a boiler exploded at a refinery, OSHA cited the refinery’s owner for violating 29 C.F.R. § 1910.119, which sets forth requirements for the management of highly hazardous chemicals. The Occupational Safety and Health Review Commission (the Commission) upheld the violations. In doing so, it noted that the refinery had previously violated § 1910.119. But…...

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LOTO is NEVER based on how “slow it moves”, even when it is 1 revolution/10 minutes

Have you ever been told… “it moves too slow to be a hazard”?  If you stay in the safety profession long enough, you will be presented with this viewpoint.  But LOTO is NEVER about how slow something moves; there is no exemption in the standard for such a thing.  Here is a case we can…...

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Emergency Response Coordination Activities Effective Date(s)

The RMP Amendments finalized on January 13, 2017, included a requirement for owners or operators of a stationary source to engage in emergency response coordination activities (40 CFR §68.93).  The regulatory text in 40 CFR §68.10(b) states that compliance with these activities must be completed by March 14, 2018.  Because the RMP Amendments were not…...

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