Safety Info Posts

EPA RMP citations @ meat processing facility (NH3 & $156K)

Respondent is the owner and/or operator of a meat processing facility that uses, handles, and/or stores more than a threshold quantity of anhydrous ammonia. Respondent is required to prepare and implement an RMP to detect and prevent or minimize accidental releases of such substances under section 112(r)(7) of the CAA. Respondent meets the Program 3…...

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Aircraft/fuel truck collision highlights importance of following safety directives during emergencies (TSB of Canada)

The Transportation Safety Board of Canada (TSB) has released its investigation report (A19O0063) into the May 2019 collision between a fuel truck and a plane at Toronto/Lester B. Pearson International Airport, Ontario. The investigation highlights the importance of passengers familiarizing themselves with safety information and following instructions from flight attendants during emergencies. On 10 May 2019, at…...

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Listings of Chemicals Likely to Undergo Self-Polymerization (DOT ERG = P)

The DOT ERG identifies chemicals as being shipped “inhibited” or “stabilized” and have a “P” listed with their guide number meaning that the chemical can polymerize. These inhibitors are TIME and TEMPERATURE dependent! The inhibitors can be tested and more inhibitor added if necessary, albeit VERY RISKY once the reaction has begun AND the fact…...

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A PHA is not a JHA; a JHA is not a PHA

Both of these tools are necessary in the process safety arena; however, they have very different and distinct roles in process safety management.  In my career I found it best to perform the PHA first and based on the deviations identified in the PHA, we would write our SOPs to cover those deviations.  And of…...

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Differences between a BLEVE and a HIT (2020 & 2024 ERG)

UPDATED on 4/4/24 with 2024 ERG Info   This week we saw the official release of the 2020 Emergency Response Guide (ERG) from DOT/PHMSA and along with this 2020 update came some clear distinctions between a “Heat Induced Tear” (HIT) and a Boiling Liquid Expanding Vapor Explosion (BLEVE). (emphasis by PHMSA) A Heat Induced Tear…...

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More on the limitations of Excess Flow Valves – 9 out 10 times they may let you down when you really need them

Yes… here we go again!  If we wish to claim an Excess Flow Valve as a “layer of protection” against a hose/pipe failure, we then MUST ensure the device is SIZED properly, INSTALLED properly, OPERATED properly, and MAINTAINED properly.  This is what is called process safety management and for the life of me, I just…...

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Changes between the 2016 and 2020 editions of the Emergency Response Guidebook (ERG)

The Emergency Response Guidebook (ERG) 2020 is finally here! We’ve listed the most important changes from the 2016 edition to the 2020 edition. They’re listed based on the color of their section in the guidebook. White Pages:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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FATAL PRCS accident; Explosion (Flammable atm & $44K)

On or about January 11, 2020, employees engaged in performing cleaning and maintenance on a heater treater system with a combustible engine power washer within range of flammable material stored within the heater treater were exposed to burn hazards…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log...

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OSHA issues Willful GDC 5(a)(1) Citation for fatal Propylene Explosion (Propylene & $143K)

I am going to guess that the facility’s inventory was less than 10,000 pounds of Propylene as OSHA issued no PSM citations, only a HAZCOM training citation and a GDC citation for four (4) issues they found with how the flammable gas was managed.  Another incident showing OSHA’s weakness with “flammable gases”; they NEED a…...

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Verification of Zero Energy State (ZES) and Specific Procedures

One of the more popular findings in our LOTO assessments/audits involves the lack of specific procedures for verifying a zero energy state (ZES) for EACH energy source.  The LOTO standard, 1910.147, makes it clear that the energy control procedure must be “specific.”…… Membership Required You must be a member to access this content.View Membership LevelsAlready...

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PRCS Rescue and Emergency Services (1926.1211)

As the debate continues to rage regarding the types of PRCS rescue and when they are required, OSHA has seen fit to publish the following: (emphasis by me) Effective emergency planning is vital to ensure that any entrant who becomes sick or is injured in a permit space can be evacuated quickly and safely. The…...

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