Safety Info Posts

Can the partial pressure exemption be applied to formaldehyde solutions?

Formaldehyde is not specifically listed with a concentration cutoff, but is listed with the qualifier “solution”. Can the partial pressure exemption be applied to formaldehyde solutions?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Types of Information Relevant for Response Planning (RMP 68.93(b))

The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency planning and response organizations identify…...

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EPA RMP citations @ Chlor-alkali manufacturer (Cl2 & $87K)

On August 18, 2018, the EPA issued to Respondent a Notice of Potential Violation (“NOPV”), providing notice that the EPA found that Respondent had potentially committed the alleged violations described in Section V of this Agreement and providing Respondent an opportunity to confer with the EPA. On February 14, 2019, representatives of Respondent and the…...

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ERG 2020 Mobile App is now available

The Pipeline and Hazardous Materials Safety Administration (PHMSA) has developed a free, mobile web app of its Emergency Response Guidebook 2020 (ERG). The new safety tool provides the nation’s emergency responders with fast, easily accessible information to help them manage hazardous material incidents. This software is available from the Apple iTunes store for iPhone, and…...

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Process Safety and our primary containment systems

A wise plant manager told me this in my first year in the petrochem industry.  I am paraphrasing When it comes to our primary containment systems (he was speaking to piping in this discussion) – if it is not done darn near perfect, all we have to do is wait a while and bad things…...

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OSHA Fire Brigades and their management program(s)

OSHA does not mandate that employers establish fire brigades; however, if they do so, they must comply with the provisions of the Fire Brigades Standard. The provisions of the standard, including the paperwork requirements, apply to fire brigades, industrial fire departments, and private or contract fire departments, but not to airport crash rescue units or…...

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RMP Emergency response coordination activities effective date

As I stated last week and posted my updated RMP Audit Checklist ER questions, the RMP ER coordination activities should be at least in your “planning/discussion” phase with your off-site responders/resources.  Even though 68.10(b) states that compliance with these activities must be completed by March 14, 2018 and the fact that the amendments did not…...

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Anhydrous Ammonia, nitrification inhibitor, and EPCRA Sections 311 and 312 reporting

Back in December 2017, I wrote an article explaining how this new nitrification inhibitor in the ammonia fertilizer industry would impact the facility’s PSM/RMP programs.  I received a lot of questions and nasty grams from that article, but one thing I forgot to mention is how this new “blending” operation changes the retail locations EPCRA…...

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NFPA 350, Guide for Safe Confined Space Entry and Work Updates/Revisions

Today, the NFPA adopted some interesting revisions to their NFPA 350, Guide for Safe Confined Space Entry and Work.  One item that many may find interesting is 8.6.5 Pipes and lines that run through a confined space… Here are the most notable updates/revisions: Non-Members can find the changes Here…. Membership Required You must be a...

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Updated PSM/RMP Audit Checklist with EPA Emergency Response updates

For SAFTENG clients and members, I have updated my PSM/RMP audit checklist (the old OSHA PQV checklist) with EPA’s most recent amendment regarding the Emergency Response requirements for Responding and Non-Responding facilities.  Keep in mind that these new requirements are “officially” ONLY required when the facility is an RMP facility; if the process(s) is ONLY…...

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Bolted flanges – sweat the small stuff (LPG Jet Fire)

One (1) bolt on a five(5) bolt flange was left loose by just one full turn and we have a small release of a flammable gas… EXCELLENT video by Baker Risk…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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