Safety Info Posts

If OSHA adopts Part 2 of the UN’s GHS, what will Flammable Gases look like?

As we discussed last week, the 7th Edition of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) has quite the change as it relates to flammable gases.  We now know there are three (3) Categories of flammable Gases:  1A, 1B, and 2.  The 1B is the new one and was in put…...

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Watson Grinding Tragedy (RMP Comp, Video, and Photo Analysis)

First thing – Rest In Peace Gerardo Castorena and Frank Flores and may God be with your loved ones during this most difficult time.  Also to the residents who have lost their homes and/or been displaced, I wish you a speedy return to some sense of normalcy.  And to the workers who have lost their…...

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Gas Pump Safety – USA Style (Video)

Each time I share a video of foolishness putting people at risk I always catch slack from people in the USA about how the video shows “3rd world behaviors” – never mind all the videos and pics showing Americans at gas pumps using plastic bags, 5-gallon buckets, etc. at fuel pumps.  Here is another one…...

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OSHA’s Process Safety Management and EPA’s Risk Management Plan Regulatory Requirements along with the CCPS Risk Based Process Safety Elements

During stakeholder outreach as part of EO 13650 and during OSHA’s PSM SBREFA (Small Business Regulatory Enforcement Fairness Act), OSHA and EPA received multiple comments from stakeholders expressing confusion on the applicability and overlap between OSHA’s Process Safety Management (PSM) standard and EPA’s Risk Management Plan (RMP) regulation. In the Clean Air Act Amendments of…...

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Process Safety is blowing in the political winds (GHS and Flammable Gas Categories)

I have written over a dozen articles on the big change in automobile manufacturing and their new refrigerant HFO-1234yf which is going into almost all vehicles made today.  Today HFO-1234yf is a Category 1 Flammable gas, hence it is a Highly Hazardous Chemical (HHC) and when the process exceeds 10,000 pounds of this refrigerant the…...

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Using a Voltmeter is ENERGIZED electrical work!

I am not an electrician, I don’t even consider myself a Qualified Electrical Worker, but I do know Electrical Safety-Related Work Practices (and I stayed at a Holiday Inn Express last week). I do not do a lot of electrical safety training (except for existing clients), but it seems that every time I have done…...

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Reclassifying a PRCS to a Non-PRCS is more than just locking out energy sources!

Too many safety professionals still to this day think that to reclassify a Permit-Required Confined Space (PRCS) is simply to lock out all the energy sources that made the space a PRCS.  In August of last year, I posted a story where I asked the 30,000 members of the SAFTENG network if an enclosed palletizer…...

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EPA EPCRA/CERCLA citations for two (2) Ammonia releases ($82K)

“Minor” LOPC events that are allowed to continue over a weekend can be a COSTLY MISTAKE!  Any LOPC event MUST be reported ASAP to that it can be addressed, regardless of how “minor” it may be considered!  We have to keep our HHC/EHS’s in their PRIMARY CONTAINMENT and when we have a failure that lets…...

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OSHA PSM Citations @ Refinery (HF Acid & $132K)

OSHA has cited a refinery for serious violations of safety and health hazards related to process safety management (PSM) following a fire and subsequent explosions at the company’s Refinery Complex in June 2019. The company faces $132,600 in penalties.  OSHA’s inspection found deficiencies in the refinery’s PSM program, including failing to establish or implement written…...

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Line Break gone bad (Natural Gas Condensate w/ flash fire)

Opening a Natural Gas Condensate line with a battery-operated drill inside a compressor building is ASKING for trouble.  Basic HAZLOC work practices include using INTRINSICALLY SAFE tools that are APPROVED for the HAZLOC, which has been an OSHA requirement since 1981… 1910.307(c) Electrical installations. Equipment, wiring methods, and installations of equipment in hazardous (classified) locations…...

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EPA RMP Program 2 citations @ agriculture retail facility (NH3 & $71K, w/ $55K SEP)

Respondent is the owner and operator of a facility that had greater than 10,000 pounds of anhydrous ammonia in a process at each of its facilities. From the time Respondent first had onsite greater than 10,000 pounds of anhydrous ammonia in a process, Respondent was subject to the requirements of 40 C.F.R. Part 68 because…...

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EPA RMP citations @ chemical supply outlet (Cl2 and SO2 & $100K)

Respondent owns a chemical supply outlet where chlorine was present in a process above the 2,500 pounds TQ, and sulfur dioxide was in a present in a process above the 5,000 pounds TQ from at least March 16, 2010. Respondent has two (2) program 3 processes: a chlorine cylinder storage process, and a sulfur dioxide…...

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