The RMP CAFO is very interesting in that the facility stated they were under 10,000 pounds (NH3 TQ) and EPA challenged their numbers, even though the facility had completely pumped down their system and had exact pounds they charged the system with when they started up. So the case is going to court and EPA…...
I recently received a question from a client about “piping inspection methods for newly installed piping”. It seems that a general contractor was advising the facility that they were “required” to do some “thickness testing” on newly installed piping as part of the installation QA/QC. The PSE asked me “So are we required to take…...
This is an EXCELLENT LOI from OSHA that covers three (3) IMPORTANT aspect of PSM applicability: Co-Location of smaller containers of flammables that could be impacted by a single event (i.e. fire) Once a process is PSM covered it remains such UNTIL such time the employer puts in place a means to LIMIT the quantity of the…...
Scenario: An employee experienced an injury when sharpening a personal pocket-knife while sitting in a company owned-truck parked in the employer’s parking lot. The employee lacerated the palm of his hand and was treated with seven sutures, and the employee returned to work immediately with no restrictions. You state that because the employee was on his…...
Way back in 1994 when I was implementing my first FRC program there was a great debate on the options that would be made available to operators, maintenance, engineering, EHS, and QA/QC personnel who perform work within a HAZLOC. This debate was of course driven by costs vs. risks and luckily I was working for…...
The car manufacturers have begun using a new refrigerant for our cars and trucks air conditioning systems. This new refrigerant, HFO-1234yf, is received by truck, stored as a liquified (pressurized) gas, and dispensed into the vehicles A/C unit. The piping associated with this storage and transfer of this refrigerant must meet…… Membership Required You must...
We see a lot about Corrosion Under Insulation (CUI) as it relates to piping, but we can not forget that the same failure mode can occur on vessels as well. API 510 spells out some ranges as to when we MUST consider the need for a CUI inspection on our vessel(s)…. Membership Required You must...
Sorry for a lack of posts these last couple of weeks, they have been crazy with travel and work. But I wanted to follow-up on a lot of questions and comments I got regarding my “Internal inspections… of my pressure vessel??? We don’t need no internal inspections” post a few weeks back. If your engineers/management…...
On June 3, 2019, a railcar catatrophically failed when incompatible materials stored inside the car reacted and approximately 20,000 gallons of liquid waste derived fuel – fuel derived from hazardous waste – spewed from the railcar for 34 seconds. The eruption sent waste fuel several hundred feet into the air and ripped the manway hatch…...
Sometimes the OSHA “Request for public comments” postings contains some really good insights as to the documentation aspect to OSHA compliance. This week’s posting does a nice job of explaining all that is required to document our PPE Hazard Assessments: (emphasis by me, but 100% OSHA wording) Paragraph 1910.132(d)(1) and the Personal Fall Protection standard…...
… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
So this week we all got a chuckle when I posted this picture to my Social Media groups: But in all seriousness, this is NO laughing matter! Well, we can at least surmise that EPA inspectors do not find the humor in it, as is evident in the nine (9) labeling issues they noted in…...
