Safety Info Posts

Module of 25 horizontally-mounted high-pressure gas cylinders loaded with 240 kg of compressed Hydrogen, UN1049, caught fire

On February 11, 2018, about 1:15 p.m. a module of 25 horizontally mounted high-pressure gas cylinders loaded with 240 kilograms (kg) of compressed hydrogen, UN1049, caught fire while being transported. The incident occurred on Golden Springs Drive, near South Brea Canyon Road, in Diamond Bar, California.  About 120 kg of the hydrogen was released from…...

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Safety Alert No. 328: Gas Release Hazards Identified by BSEE

The Bureau of Safety and Environmental Enforcement (BSEE) recently conducted a review of the latest compliance and incident data to identify safety trends throughout the Gulf of Mexico. The analysis pointed to a potential risk associated with gas releases. During the timeframe reviewed, thirty-one gas release incidents were reported to BSEE by fourteen unique operators…....

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EPA RMP citations @ pork harvesting, processing, and packaging facility (NH3 & $58K)

Respondent is the owner and operator of a pork harvesting, processing, and packaging facility which utilizes 250,000 pounds of anhydrous ammonia in its refrigeration system.  On April 20, 2016, EPA inspected the Facility in order to determine the Facility’s compliance with the Chemical Accident Prevention Provisions of 40 C.F.R. Part 68.  Based upon the information…...

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EPA RMP citations @ Cold Storage Facility (NH3 & $107K)

SAFTENG NOTE:  This is the first time I have come across a citation from either OSHA or EPA where they took issue with the Ammonia Flammability Limits as depicted on the NFPA 704 Diamond located on the engine/machinery room door.  The facility had not updated their label to show NH3 as an F=3 for indoors;…...

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National Board’s position on “intervening stop valves” in Relief systems

In 2017, the NBIC was restructured into four (4) parts, adding a new Part 4, Pressure Relief Devices. This purpose of this restructuring was to provide one distinct integrated part for pressure relief devices compiled from all PRD information referenced in Part 1, Installation; Part 2, Inspection; and Part 3, Repairs and Alterations.  And in…...

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Understanding an NH3 Refrigeration “Emergency Pressure Control System”

An “Emergency Pressure Control System” has been a requirement in the IFC and IMC for several iterations of these codes, and yet it can be a very confusing requirement as they are not found in the vast majority of mechanical refrigeration systems using Anhydrous Ammonia as the refrigerant.  Part of the problem may lie in…...

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Contractors and Lockout/Tagout

Those of us under Federal OSHA can let our contractors follow their own LOTO program/practices AS LONG AS they explain them to us.  However, in some states, their OSHA plan requires contractors to support the “on-site employer’s” LOTO program.  As I have written about, most workplaces struggle to manage their contractors PROPERLY when LOTO is…...

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Line Break gone bad (Natural Gas)

Those who practice “process safety” are all too familiar with “Line/Equipment Opening” safe work practices.  Although there is NO formal OSHA standard, nor even a RAGAGEP on this extremely hazardous task, we should consider implementing a “permit” of some type to manage the risks associated with opening any pipe, line, hose, equipment that handles a…...

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Physical and Health Hazards Cross-Walk for EPCRA Tier II Reporting

I know we are past the 2018 reporting deadline (March 1st), but last week (4/10/18) EPA posted a beneficial tool for those of you who work with EPCRA Tier Sheets.  EPA and OSHA did an excellent job developing this cross-walk worksheet to assist facilities in comparing OSHA’s original and new physical and health hazards adopted…...

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WA-OSHA’s PRCS Rescue Plan Document

This year WA-OSHA (Washington State Dept. of Labor & Industries) issued their Construction PRCS standard in February.  Since this is a State Plan Standard, it had to be at least as effective or more effective than the Federal Construction Standard on PRCS’s.  With that said, the WA state’s standard does provide us with more information,…...

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Making sense of OSHA’s Construction PRCS Standard (WA-OSHA’s PRCS Construction Standard)

One of my favorite things about state plans… they often provide more insight into OSHA standards.  Take for instance the state of WA OSHA’s, called Washington State Dept. of Labor & Industries, Safety Standards for Confined Spaces document.  The state’s Construction standard on Confined Spaces closely mimics Federal OSHA’s requirements, but it is HOW the state’s standard…...

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Filtering out Confusion: Respirator Reuse and Extended Use (NIOSH)

Nationwide, approximately 1.3 million workplaces provide at least a portion of their employees with respiratory protection. One of the most common types of respiratory protection is the filtering facepiece respirator (FFR), which is designed to be discarded when it becomes unsuitable for further use due to considerations of hygiene, excessive resistance, or physical damage. However,…...

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