On August 27, 2016, about 8:26 a.m. EST, a railroad tank car sustained a 42-inch long crack in its tank shell shortly after being loaded with 178,400 pounds of liquefied compressed chlorine at a chlorine manufacturing plant in West Virginia. Over the next 2.5 hours, the entire 178,400-pound load of chlorine was released and formed…...
One of the recent amendments of EPA’s RMP rule impacted our Incident Investigation procedures/practices and most likely any report forms we had been using for years and years. The RMP and PSM Incident Investigation elements used to be very similar and thus most of us used the same procedure/practices and forms when trying to comply…...
Respondent owns and operates a chemical facility which had Chlorine (Cl2) as its “regulated substance”. On or about January 23-24, 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…...
I like direct statements and clear concise rules when it comes to drawing the lines of safety and production and maintenance. But too often, these lines get drawn in the wrong spot and cause safety all kinds of issues and let’s admit it… gives safety a bad name. One such line is when lockoout/tagout (LOTO)…...
It is important to emphasize that the machine guarding requirements of 29 CFR Part 1910, Subpart O standards COMPLEMENT THE REQUIREMENTS for LOTO. In some instances, an employer may avoid the requirements of the LOTO, if they ELIMINATE exposure to servicing and maintenance hazards by using machine guarding techniques compliant with those standards. It is also important to…...
Lockout/Tagout (LOTO) STARTS WITH machine gaurding. Yes, MACHINE GAURDING – we can not even begin to speak of LOTO until we first have the forms of hazardous energy properly gaurded for our NORMAL OPERATIONS. Because when the machine/equipment is being used for its inteded purpose(s) (e.g. Normal Operations) we are FIRST REQUIRED to ensure that…...
The state of NJ has developed a Toxic Catastrophe Prevention Act (TCPA) Program Update intended to assist regulated TCPA facilities in understanding how they are impacted by the January 13, 2017, amendments to EPA’s RMP Rule, 40 CFR Part 68. The table indicated the effective dates of the amendments, which provisions are incorporated by the…...
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This Consent Agreement and Final Order serves as notice that the EPA has reason to believe that Respondent violated the General Duty Clause set forth in Section 112(r)(1) of the CAA and the Chemical Accident Prevention Provisions in 40 C.F.R. Part 68 and that Respondent violated Section 112(r) of the CAA. Respondent’s Facility has ceased…...
Download CAMEOfm 3.5.1 at https://www.epa.gov/cameo/cameo-software Note: If you’re upgrading to CAMEOfm 3.5 from a previous version of CAMEOfm, follow the instructions in the guidance document (provided on the download page) to ensure that you don’t lose your current data. What’s changed in CAMEOfm 3.5.1? Version 3.5.1 resolves an issue in which the program could not…...
There are not very many OSHA standards that call out the “trainer qualification(s)” for those who teach on the subject matter, but the HAZWOPER standard does. When a trainer uses the phrase HAZWOPER over and over but does not recognize this is an acronymn that stands for Hazardous Waste Operations and Emergency Response, has no…...
WOW… my LOTO ppt for “Affected Personnel” that I posted earlier this week has caused quite the “back and forth” with too many people/sites. I just assumed that we had a basic understanding of “who falls into the “affected” bucket” and “what they must know”. Affected employees do NOT need to attend a 2-hour training…...
