Safety Info Posts

EPA RMP GDC @ refrigerated food distribution warehouse (NH3 & $101K)

At all relevant times, Respondent owned and operated a refrigerated food distribution warehouse with an ammonia refrigerant system which contains approximately 9,617 pounds of ammonia. EPA inspected the facility on August 9, 2018. Prior to the August 9, 2018, inspection, Respondent had not performed a hazard analysis nor developed standard operating procedures for the ammonia…...

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A PSSR is NOT an Initial Start-Up Procedure

I am not sure where or quite when this vicious rumor began, but let’s make this clear: A Pre-startup Safety Review (PSSR) is an ENTIRELY separate exercise AND MUST be completed BEFORE the Initial Start-Up procedures are implemented. Granted it may be the same personnel doing both tasks, but the PSSR is FULLY COMPLETED BEFORE…...

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Personal Fall Arrest System or Ladder Safety System on Fixed Ladders (OSHA LOI)

Scenario: In an industrial setting, a ladder starts 100 feet above grade on the side of a tower. The base landing of the ladder is only there for ladder access, so it meets OSHA minimum dimensions and is equipped with standard guardrail. The length of climb above this base is no more than 24 feet…....

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Definition of Confined Space, as it may apply to large product heating and aging furnaces (OSHA LOI)

Background Product parts are heated in the furnaces using natural gas to temperatures ranging from 700ºF to 2200ºF to facilitate material processing. The furnace doors are actuated remotely from either the cab of a forklift or a control panel. Parts are loaded and unloaded from the furnaces using forklifts during production runs. The furnaces range…...

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Personal Fall Arrest System or Ladder Safety System on Fixed Ladders, and Fixed Ladders Used on Grain Silos for Emergency Escape (OSHA LOI)

Background: Multiple sections of off-set ladders are being designed to be installed on the outside of a grain silo that is 80 feet or more in height. Rest platforms will be installed at each off-set and will be provided with guardrail systems to meet OSHA’s requirements. The rest platforms measure 3 feet by 3 feet…...

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When a Nitrogen (N2) Purge makes an A_s out of U and Me (Assume)

Earlier this year I was asked to participate in an incident review involving a flashfire/explosion in a tote-filling process. (NOTE: the official term is an Intermediate Bulk Container or IBC) As I have written about many times, the #1 cause of these flash fires/explosions inside a container/vessel is the generation of static electricity; but this…...

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OSHA PSM Citations @ Organic Chemical Manufacturer (Isobutane & $130K)

At approximately 10:40 a.m. on April 2, 2019, the housing of a three-inch Y-strainer of an isobutylene line that fed into reactor K8 ruptured and isobutylene was released, forming a vapor cloud. Three employees responded to mitigate the isobutylene vapor in the reactor area. As Employee #1 was at an old control room area and…...

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OSHA reiterates that on-line training does NOT meet all training needs

Over my career in S&H and Emergency Response, I have seen the proliferation of “on-line” training get out of control in the past 10 years.  Seems the sellers have sold the on-line delivery method as the “silver bullet” – the answer to all the training woes within an organization.  Heck even OSHA has allowed some…...

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EPA RMP Program 2 citations @ agriculture retail facility (NH3 & $20K, w/ $80K SEP)

On or about August 10, 2018, representatives of the EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had the capacity to store 650,000 pounds of anhydrous ammonia at the Facility, and regularly stored…...

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Anhydrous Ammonia exposure leads to a tracheotomy (OSHA)

This past May an employee was filling a nurse tank with anhydrous ammonia and noticed a small leak at the hose coupling.  He attempted to tighten the coupling and while doing so the coupling popped off and he was exposed to NH3 vapors. … Membership Required You must be a member to access this content.View Membership...

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Fiasco @ the Fuel Pumps #1 (2019, Gas Station Attendant scrubbing with gasoline)

Gas Station Attendant scrubbing with gasoline!!  It may be kerosene, but it is a fuel that is he spraying (splashing) onto the pavement and then spreading it out with a broom which in all likelihood is creating static.  How and Why it did not ignite makes me wonder if he was using some other fuel…...

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