Safety Info Posts

Differences in accident history between Program 1 eligibility and the hazard assessment

Program 1 eligibility under 40 CFR §68.10(b) is contingent upon the process NOT having had an accidental release of a regulated substance that led to offsite death, injury, or response and restoration activities at an environmental receptor within five years prior to the risk management plan submission. Additionally, as part of the hazard assessment required…...

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Dispersion Modeling Systems Relevant to Homeland Security Preparedness and Response

As one of its core research focuses, the U.S. Environmental Protection Agency’s (EPA’s) Homeland Security Research Program (HSRP) is interested in refining its tools and methodologies to better characterize the fate and transport of hazardous contaminants during all phases of an emergency response. Atmospheric dispersion modeling is one tool that can be used for effective…...

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Ammonia Gas Cylinders Explosion

This safety alert is issued following an incident involving two explosions of ammonia gas cylinders at an ammonia gas filling and bottling plant.  The plant has been operating for more than 20 years. The ammonia stock from the suppliers will be stored first in the bulk storage tanks with a capacity of 500 and 900…...

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Pipe Welding and Welder Qualifications (ASME B31.1 and 31.5)

If you’re installing/repairing/modifying your chemical process piping using ASME B31.3 and 31.5, these standards have some strict QA/QA requirements for who can make the welds to join the piping.  These welders MUST be qualified in accordance with ASME Code, Section IX, “Welding Qualifications.”  ASME Code, Section IX, Part QW-103.1, states that: “Each manufacturer or contractor…...

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EPA RMP citations @ chemical facility (EtO & $38K after vessel failure and release))

At the Facility, Respondent produces, processes, stores, or handles more than 10,000 pounds of ethylene oxide. On November 3, 2019, the Glycol 2 Production Unit experienced a release of ethylene oxide.  Respondent’s Glycol 2 Production Unit experienced an ethylene oxide release involving the knockout pot D-410 of the Ethylene Oxide Scrubber Process. In response to…...

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COVID safety changes may need an MOC when they impact a PSM/RMP process

We have seen hundreds of changes to our businesses since March and many of these changes were needed for worker protection, but recently we came across one such change that had serious potential to cause a bad event!  Maybe you have seen the latest and greatest devices for aiding in our “social distancing” efforts.  These…...

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Fundamentals of Hazardous Materials exhaust ventilation systems

In workplaces that handle/store hazardous materials, there is a need for exhaust ventilation systems when these “Control Areas” exceed the maximum allowable quantities (MAQ) of these hazardous materials.  I have used the International Mechanical Code (IMC) as my baseline code for 20+ years.  We see this code’s basic requirements in a lot of OSHA standards…...

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EPA RMP citations @ pesticides facility (Cl2 & $77K after leak)

Respondent operated a facility to store and distribute pesticides, fertilizers, and industrial chemicals, including chlorine. At all times relevant to this CAFO, the facility produced, used or stored more than 10,000 pounds of chlorine and was subject to the requirements of CAA § 112(r)(7). The process was subject to Program 3 requirements because it was…...

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Deficiencies in Process Piping Cause Gas Release Incidents (QA and MI programs)

An increased number of gas release incidents have occurred in the Gulf of Mexico Region due to leaks from cracked welds, ring gaskets, flange gaskets, inlet nozzles, pipeline risers, suction headers, pressure safety valves (PSVs), and fuel gas lines. These gas release incidents involve deficiencies in Quality Assurance and Mechanical Integrity programs and are caused…...

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Static electricity ignites acetone vapors and destroys barge (NTSB)

The National Transportation Safety Board determines that the probable cause of the explosion aboard the barge IB1940was the company’s incomplete procedures that did not incorporate the safety instructions included in the Facility Operations Manual regarding the electrical bonding of air movers to barges, resulting in an unbonded air mover being operated in a cargo tank…...

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My Group Lockout – Lockbox method

This is a written explanation of how I was taught to perform Group Lockout and how to manage contractors working on-site under a Group Lockout.  There are many things in this document that are NOT required by OSHA; however, they are in the program to ensure compliance with OSHA’s minimum expectations.  We did it this…...

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EPA RMP citations @ petrochem facility (Flammables & $33K after pipe failure (CUI) led to an LOPC event)

Respondent is the owner and operator of a facility where on October 13, 2019, there was an incident at the Facility that resulted in an accidental release. On April 4, 2020, the EPA requested, and Respondent provided, documentation and information concerning the Incident and Respondent’s compliance with Section 112(r) of the CAA and 40 C.F.R…....

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