Safety Info Posts

Process safety failures led to the fatal Styrene release in India last month

Today, the Indian government released its investigation findings regarding the fatal Styrene release on May 7, 2020, which killed 12 citizens and hospitalized 585 others.  This incident, like the many before it, came about by a number of failures the facility/company made in the management of their Styrene inventory.  In the light of the root…...

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EPA RMP citations @ polymer manufacturing plant (Flammables & $48K)

PLEASE NOTE this entire inspection citation is based on the facility not having their piping labeled per ASME A13.1 – A13.1-2015, Scheme for the Identification of Piping Systems Respondent is the owner of a polymer manufacturing plant and based on the observations of EPA inspectors during the Inspection, EPA has determined that Respondent has handled…...

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Canada is proposing some interesting revisions to their Confined Space standard

In 2014, Part XI – Confined Spaces was identified as a priority for review by the Labour Program’s Occupational Health and Safety Advisory Committee (OHSAC). The OHSAC made up of representatives from the Labour Program and employee and employer groups, conducted an in-depth review of Part XI between 2014 and 2017. The proposed changes are…...

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The sad state of Hazard Communications in safety

It’s been 8 years since we have been using the Globally Harmonized System for our Hazardous Communications.  This much-needed update to OSHA’s HAZCOM standard was intended to correct many bad practices and to “harmonize” the USA with the rest of the world.  One of the big drivers for this change was the need to formalize…...

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NH3 2,100 pound NH3 LOPC event exposes eight (8) workers, one hospitalized ($119K)

On January 27, 2019, 12 employees needed transport to nearby hospitals after a a release of 2,100 pounds of anhydrous ammonia.  OSHA cited the facility for failing to: Equip an ammonia refrigeration system with a pressure relief device as referenced by the manufacturer’s operating manual; Train technicians to use an alternative over-pressure safety procedure to…...

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OSHA issues willful and repeat citations for a double fatality PRCS entry into a tank trailer ($497K)

OSHA has cited a container cleaning business for exposing employees to confined space hazards after two employees were fatally overcome by fumes while cleaning a tank trailer. The company faces $497,920 in penalties. OSHA investigators determined that one employee became unresponsive after entering the trailer’s confined space. After a non-entry retrieval system used to rescue…...

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Nitrogen Gas generator for fixed water-based fire suppression systems

Nitrogen… an often misunderstood SAFETY gas that many fear and for good reason!  Imagine you have a flammable liquid that has a Flash-PointP<100°F and you worry about static or other ignition sources causing an event inside your storage container… what can I do to lessen the risk of a fire/explosion in the headspace of my…...

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Fabrication and Field Testing of Refrigerant Piping (ASME B31.5)

One of the most requested slide deck over the years has been from my 5-Day RAGAGEP course, specific to ASME B31.5, Refrigeration Piping and Heat Transfer Components.  The PowerPoint file below is only 12 slides from a 300 slide presentation, but the requirements noted in these 12 slides are often not understood at the plant…...

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Is the space below the raised floor in a semiconductor facility a PRCS?

I spent several years working at semi-conductor facilities (the Cincinnati SUMCO plant was one of the finest!) and it was world’s apart from a chemical facility.  When I worked in chemical plants we always used to say… “this ain’t no chocolate factory”.  But when I arrived at SUMCO I swear it was cleaner than any…...

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Cigarette lighters in pockets during hotwork – Allow or Prohibit?

Does your business allow workers to carry their personal lighters in their pockets?  In my word of Flammable Liquids and Gases (FLAGs) and HAZ MATs we never allowed people to have lighters on them while on our property – some companies do not even allow them in parking lots. In most of my plants, our…...

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OSHA Interpretation on Connected Processes managed by two different companies, but on the same contiguous property controlled by an employer or group of affiliated employers

7/8/20 UPDATE: this LOI was NOT removed from the OSHA website; it was merely MOVED to the Year 2017 LOI Page (Linked Below).  The letter was MOVED without any changes to its content – it was just moved to its proper year.  This was merely a recordkeeping move by OSHA to reflect the year the…...

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EPA RMP Program 2 citations @ two agricultural storage facilities (NH3 & $120K)

Respondent is a cooperative with two (2) facilities that store ammonia. On June 26th and September 6, 2012, EPA conducted inspections of the facilities to determine the Respondent’s compliance with the Risk Management Program 2 Prevention Program requirements. The inspections confirmed that the facilities had more than a threshold amount of anhydrous ammonia. Facility #1…...

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