Safety Info Posts

Boston Seafood Distributor to Pay $700K for RMP GDC Violations

A seafood distribution company that formerly operated in Boston, Mass. will pay a cash penalty, subject to court approval, settling allegations by the U.S. EPA that the company violated federal environmental laws relating to the use of anhydrous ammonia, sulfuric acid, and lead at its facility. Under the settlement, the company has agreed to pay…...

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EPA RMP record citations @ refinery (Flammables & $2.95M civil, $150M in upgrades/repairs, w/ $10M SEP)

NOTE: The overall value of this settlement exceeds $160 million, which makes it the largest settlement in the history of the EPA’s enforcement of the Risk Management Plan Rule under Clean Air Act Section 112(r). This is also the first case in which the United States and a state have jointly brought suit to enforce…...

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OSHA’s 2017 Top 10 Violations

The 2017 Top 10 violations, from both General Industry and Construction, are: #1 – Fall Protection, Duty to provide (29 CFR 1926.501): 7,270 violations #2 – HAZCOM (29 CFR 1910.1200): 4,552 violations #3- Scaffolds – general requirements (29 CFR 1926.451): 3,336 violations #4 – Respiratory Protection (29 CFR 1910.134): 3,118 violations #5 – Lockout/Tagout (29 CFR…...

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OSHA Due Dates for some fixed ladders is November 19, 2018

As November is just around the corner, we are reminded of a couple of OSHA Due Dates regarding the revised Walking and Working Surface Standards.  Coming up next month we have:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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EPA RMP GDC citations @ pet food manufacturing facility (NH3 & $89K, w/ $90K SEP)

Respondent operates a facility where it processes fish to produce ingredients used by pet food manufacturers. The Facility is located in a designated industrial area within approximately 300 feet (0.05 mile) of JFK Memorial Highway, less than 500 feet (0.09 mile) from the nearest residence, and approximately 600 feet (0.11 mile) from Buzzard’s Bay. At…...

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EPA RMP citations @ chemical facility (NH3 & $20K, w/ $76K SEP)

Respondent operates a chemical manufacturing which has 2,400,000 pounds of ammonia in onsite storage. Respondent has one RMProgram level 3 covered process. On August 16, 2017, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing the compliance with the RMProgram requirements and the implemented recognized and…...

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What is “corrosion allowance” and why should I care about it?

Simply put, “corrosion allowance” is an extra amount of thickness added to the thickness of the pipe/vessel wall based on the expected exposure the pipe/vessel may see during its lifespan. Typically, my experience has been that corrosion allowance has a safety factor equivalent to 2 when the vessel/pipe was knowingly going to be exposed to…...

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EPA RMP citations @ food and cold storage facilities (NH3 & $70K)

Respondent owned and operated two food warehousing facilities. One is used for food manufacturing and refrigerated warehouse and storage and the other is used for refrigerated storage. Respondent, as owner/operator of the Facilities, has handled and/or stored anhydrous ammonia at an amount greater than the threshold quantity of 10,000 pounds in a process since at…...

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Flame-Resistant Clothing and emblems (and reflective striping) on the garments (Size now matters!)

If you have been too busy to read the latest edition of NFPA 2112 (e.g. 2018), oh boy have you missed some fun reading.  For the most part, the standard is the same, but there are some significant nuggets that stand to impact a lot of facilities, especially those who allow “emblems” on their FRC. …...

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Is Chlorine a “Highly Toxic” or just a “Toxic” HAZMAT?

Once again I go to the well that just keeps on giving guidance… the International Fire Code (IFC). And again I do this as OSHA nor EPA have any standards for Chlorine when the amount is below the 1,500 pounds for OSHA’s PSM standard to apply. Of course, there is EPA’s RMP General Duty Clause,…...

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