This month’s CCPS Process Safety BEACON is about energy isolation practices in chemical process units and although I personally think they missed the mark on this one, it is a PERFECT EXAMPLE as to why many businesses involved with processing Highly Hazardous Chemicals/Extremely Hazardous Substances do NOT allow for “single valve isolation”, especially when there is NO…...
Last week we saw a HAZMAT incident where over 50 workers were transported to medical facilities after ferric sulfate and sodium hypochlorite (bleach) were mixed together. From recent press updates, what happened on Wednesday (2/27/19) sure does sound like a truck carrying one of these chemicals was unloaded into a tank of the other chemical. The details…...
This incident is a tad dated (2016) but it is a perfect example of how a contractor doing work “adjacent” to a covered process can impact that process. It is also a great opportunity to discuss how to establish the process “battery limits”. I like to call this my “force field” around my process –…...
Respondent owns and operates the winery facility that crushes grapes to produce wine, distilled spirits and juice for concentrate at its Facility. These products are stored prior to shipment to other facilities for further packaging and distribution. In September and November 2015, EPA performed inspections of the Facility pursuant to Section 112(r) of the, CAA,…...
I recently came across some interesting RMP data from the state of North Carolina (NC), one (1) of the nine (9) states granted delegation of EPA’s authority to implement and enforce the risk management program rule. It is only a very small percentage of RMP covered facilities, but these data and trends may be the…...
As we have discussed here many many times, pressure testing of our primary containment systems for our hazardous materials is an absolute necessity to ensure the integrity of our construction/installation and/or alteration/repair. But these tests come with some serious risks, EVEN HYDROSTATIC TESTING is a very hazardous activity. And as shown in the OSHA investigation…...
I have written about interlocks and their design, use, and function many times. I have also shared accidents which involved the abuse and/or misuse of interlocks. Sadly I have another fatality to report where an interlocked guard was by-passed… At 2:20 p.m. on June 11, 2018, an employee was mixing powders using a commercial horizontal…...
OSHA recently posted a Letter of Interpretation where they reference their Compliance Directive, Inspection Procedures for the Respiratory Protection Standard, CPL 02-00-158, and the standard’s preamble in establishing the medical evaluations for “voluntary use” of negative pressure (tight-fitting) respirators. This issue has been made clear in the CPL for years, but I thought I would share the LOI…...
Recently OSHA issued a General Duty Clause citation for “overhead process piping not properly secured causing excessive vibration” and the standard they referenced was 2007 National Board Inspection Code Part II, Section 2, Inspection 2.4.4(d) The citation was classified as “serious” and came with an $11,934 fine…. Membership Required You must be a member to access this...
Respondent is the owner and operator of a food service distribution facility. On October 18, 2017, EPA conducted an inspection of the Facility to determine the Facility’s compliance with Section 112(r)(1) and (7) of the CAA, 42 U.S.C. § 74 12(r)(l) and (7), and the Chemical Accident Prevention Provisions of 40 C.F.R. Part 68 (“Inspection…...
OSHA has cited an asphalt paving contractor after an employee suffered fatal injuries after being pulled into an unguarded slat/drag conveyor at the company’s North Platte, Nebraska, asphalt plant. OSHA proposed penalties totaling $89,032. OSHA cited the company for seven serious violations of machine guarding, lockout/tagout and permit-required confined space standards, including failing to develop a…...
The business has operated a meat processing facility since 2013. The Facility uses 30,000 pounds of anhydrous ammonia in its refrigeration system at the Facility. EPA alleges the facility failed to ensure that its anhydrous ammonia refrigeration equipment complied with recognized and generally accepted good engineering practices, in violation of Section 112(r)(7) of the CAA…...
