The 2024 edition of the International Fire Code has a new “table” that lists several exemptions. These exemptions come with some limitations, such as… Exempted materials and conditions listed in this table are required to comply with provisions of this code that are not based on exceeding maximum allowable quantities inSection 5003. Here are a…...
New HAZMAT exemptions (2024 IFC) Read More »
This was NOT intended to be directed at safety, but damn, if we look at all 13 through the lens of “barriers to world-class safety,” they sure do resonate. I have bolded my Top 3; which are your Top 3? 13 Brutal Truths Every Employer Needs to Know:… Membership Required You must be a member...
13 Brutal Truths Every Employer Needs to Know (Arpad Szakal, ACC) Read More »
Both OSHA and EPA require PSM/RMP facilities to include procedures for “responding to small releases” in their Emergency Action Plans 1910.119(n) Emergency planning and response The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan shall…...
Responding to “small releases” Read More »
A loss of containment and subsequent release of fluids can cause adverse consequences (i.e., impact safety, health, and environment, cause production losses, andincur maintenance and reconstruction costs). The risk analysis should consider the nature of the hazards and ensure that appropriate factors are considered for the equipment items being assessed. Flammable Events (Fire and Explosion)…...
Understanding our LOPC Flammable and Toxic Risks Read More »
29 CFR 1910.119(f)(1) The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
OSHA issues Car-Seal citations (Relief Protection System) Read More »
I am never disappointed in social media’s ability to tell me daily just how bad traditional safety practices are. I am also wondering if there is an aspect of business management that gets beat up and denounced more than safety. It seems we are never without so many new options/directions in safety, and unfortunately, many…...
[My] Weekly Safety Thought – Give the traditional SMS a chance Read More »
In process safety circles, the word “remote” is found in several codes/standards. In OSHA’s Process Safety Management standard, we find it used in the Normally Unoccupied and Remote Facility (NURF) exemption (1910.119(a)(2)(iii). OSHA did us a favor by officially defining this phrase; however, they have never QUANTIFIED it. Normally unoccupied remote facility means a facility…...
Defining and Quantifying the term “Remote” Read More »
The following changes will be made to Guide 115 in the 2024 edition of the ERG:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Changes coming to Guide 115 (LNG) in the 2024 edition of the ERG Read More »
Respondent owns and operates a cheese manufacturing facility. On March 22, 2022, EPA performed an inspection of the Facility to evaluate compliance with CERCLA Section 103, EPCRA Sections 304-312, and CAA Section 112(r). Based upon the information gathered during the Inspection and subsequent investigation, EPA determined that Respondent violated certain provisions of CERCLA, EPCRA, and…...
EPA issues RMP & EPCRA citations @ food facility (NH3 & $229K w/ $179K SEP) Read More »
On August 23, 2023, an employee was troubleshooting an unscrambler machine malfunction. The employee walked around to the bottom of the support frame of the machine, near two parallel drive chains. A coworker restarted the machine, and the employee was pulled into the machine by the drive chains. The employee was killed. Source: https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1693870.015… Membership...
It happened again… coworker turns on machine that a worker was “trouble-shooting” Read More »
This “process” must be in place within any SMS Incident Management Element, including a Process Safety Management System. This process is used for ALL UNPLANNED events, not just EHS-related events. Although this process appears simple, it can be full of challenges and very error-prone, eroding trust and credibility. There can be variations in each step…...
Reporting, Investigation, Causal Analysis, Corrective Actions, and Tracking Process Read More »
On May 23, 2023, @ 9:00 a.m. Employee #1 and Employee #2, both maintenance workers for a petroleum refinery, were troubleshooting an automated valve in the “Prime G Unit.” Flammable gasoline/hydrocarbons in the piping and flange portion of the automated valve were released, causing an explosion, and fire…. Membership Required You must be a member...
Line Break gone bad (Flammable gasoline/hydrocarbons) Read More »
