Safety Info Posts – Page 295 – Safety Engineering (SAFTENG)

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

October 6, 2019 / Free, OSHA Compliance / Bryan Haywood

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 […]

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

National Board turns 100 on 12/2/2019

October 3, 2019 / Chemical Process Safety (PSM/RMP), Free / Bryan Haywood

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

October 3, 2019 / Chemical Process Safety (PSM/RMP), Free / Bryan Haywood

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

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

October 3, 2019 / Free, Permit Required Confined Spaces / Bryan Haywood

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

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

October 2, 2019 / Chemical Process Safety (PSM/RMP), Free / Bryan Haywood

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

EPA RMP Citations @ seafood plant (NH3 & $30K)

October 1, 2019 / Free, PSM and RMP Citations/Analysis / Bryan Haywood

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

Piping inspections during installation (API 570)

September 29, 2019 / Chemical Process Safety (PSM/RMP), Free / Bryan Haywood

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

PSM and Aerosol (Flammable Gas) Containers Stored in Warehouses/Distribution Centers

September 29, 2019 / Chemical Process Safety (PSM/RMP), Free / Bryan Haywood

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

Determining whether an injury would apply to the work-related exception personal task and outside the assigned working hours

September 29, 2019 / Free, OSHA Compliance / Bryan Haywood

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

Flame Resistant Lab coats don’t belong in Process Areas

September 29, 2019 / Free, OSHA Compliance / Bryan Haywood

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

Why some refrigerant piping falls into ASME B31.3 rather than B31.5

September 15, 2019 / Chemical Process Safety (PSM/RMP), Free / Bryan Haywood

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…