Safety Info Posts

EPA RMP citations @ brewery (NH3 & $0K)

Respondent is the owner and/or operator of a Brewery which uses, handles, and/or stores more than a threshold quantity of anhydrous ammonia, a regulated substance, as specified at 40 C.F.R. §§ 68.115 and 68. 130. Pursuant to CAA section 112(r)(7), Respondent is required to prepare and implement a risk management program to detect and prevent…...

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Does the HCS apply to universal waste, which is included within the definition of hazardous waste and subject to 40 CFR 273? (OSHA LOI)

Question 1: Does the HCS apply to universal waste, which is included within the definition of hazardous waste and subject to 40 CFR 273? Response: No. As noted in the background section, per 29 CFR 1910.1200(b)(6)(i), the HCS does not apply to hazardous wastes regulated by the U.S. Environmental Protection Agency (EPA) under the Resource…...

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Hot Work Incidents Involving NH3 Refrigeration Facilities (NFPA Data 2011)

With the recent Hot Work fire in KS at a beef processing plant, I was looking for my posting regarding the 2011 NFPA Loss Report(s) for refrigeration facilities and realized it had not made the move over to the new website.  So here it is again.  Some really good loss data in here(albeit it is…...

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EPA RMP citations @ refinery (HF & $0K)

Respondent is the owner and/or operator of an Oil Refinery which uses, handles, and/or stores more than a threshold quantity of Flammable Mixture and Hydrogen fluoride/Hydrofluoric acid, which are regulated substances, as specified at 40 C.F.R. §§ 68.115 and 68.130. The EPA conducted an inspection of the Facility from August 15 to August 18, 2016,…...

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OSHA and NFPA Breathing Air Compressor testing and postings

Those of you that have been reading my materials for the past 20+ years know that I can be rather extreme when it comes to critical safety items such as SCBA’s used in IDLH atmospheres.  I make no apologies for my positions and my directness – heck I think more of you need to be…...

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NFPA 77 and the use of jumper cables and star washers at flanges

One of, if not the most critical, aspect of flammable liquids/gases piping is the bonding and grounding of the piping. And unfortunately, this “safety system” is often neglected and not managed as a PREVENTION LAYER of protection. It’s not like we don’t have good guidance in this need; NFPA 77: Recommended Practice on Static Electricity…...

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Regional Emphasis Program for Fertilizer Grade Ammonium Nitrate (FGAN) and Agricultural Anhydrous Ammonia Facilities

The intent of this Regional Emphasis Program is to encourage employers to take steps to address hazards, evaluate facilities to determine if the employer complies with all relevant OSHA requirements, and help employers to correct hazards, thereby reducing potential worker injuries, illnesses, and deaths. Region VII OSHA proposes accomplishment through outreach and enforcement activities. Outreach…...

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EPA RMP @ fresh produce storage and distribution facility (NH3 & $30K w/ $105K SEP)

Respondent owns and operates a fresh produce storage and distribution facility comprised of approximately 35 acres that includes cold room facilities and ice making equipment. An ammonia refrigeration system is used to cool fresh produce while in storage and for shipment at the Facility. On September 13, 2017, EPA performed inspections of the Facility pursuant…...

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There is a BIG difference between a Compressed Gas and a Liquified Pressurized Gas (and it matters immensely!)

It has been a while since we have mentioned/discussed the refrigerant HFO-1234yf – which has taken the car manufacturer’s on a ride down the PSM lane of H_LL!  I have had several discussions with these businesses and for the life of me, I am puzzled as to where this idea that NFPA 55: Compressed Gases…...

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OSHA PRCS Citations @ Refinery (Contractor lost breathing air; $106K)

OSHA has cited two companies following an employee’s death at a refining facility.  The contractor and the facility collectively face over $106,000 in penalties after the contractor’s employee suffocated to death when he lost his air supply while on the job in a confined space at the facility. OSHA cited the industrial contractor for failing to…...

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NFPA 58 (the leading Flammable Gas code) updated to 2020 Edition

With the absence of an OSHA Flammable Gas standard I have been using NFPA 58 since 1994 and it is one of my all time favorite RAGAGEPs.  I am always pushing clients to use it for their flammable gases, as well as the IFC Chapter 58, especially when their flammable gases are stored/processes/handled as a…...

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