Here we have a darn near perfect example as to why OSHA/EPA are now asking businesses with PSM/RMP covered process to “justify” their “maximum intended inventory(s)” of their Highly Hazardous Chemicals (HHC)/Extremely Hazardous Substances (EHS). The business had, at the time of the EPA inspection four (4) 1-ton cylinders of Chlorine in the same room…...
For years, OSHA had taken a position on when/where “swing gates” were actually required and that position was that it did NOT apply to fixed ladders on the edge of a platform. Then in 2009 they officially stated their enforcement position in a Regional Memo that DID include ladderway opening on the edge of a…...
NOTE: This case, as unfortunate as it is, stands in a very small group of State Fire Code violations, and in my memory stands atop of the pile @ $302,500. It is rare for a state to issue code violations and even more rare for the dollar amount to be so high. The one thing…...
Respondent owns or operates three (3) fluid milk production facilities located in MI, IL, and MO (until operations ceased in 2014). At each of these facilities, Respondent operates or operated at all times relevant to this CAFO a closed-loop refrigeration system which utilizes or utilized anhydrous ammonia. Each system uses and stores, or used and…...
Respondent owns and operates a petrochemical facility which manufactures specialty chemicals in a variety of operating units. Respondent produces, processes, handles, or stores one or more regulated substances listed in 40 C.F.R. Part 68 above the threshold quantity. In April 2016, Respondent began work to replace a tube exchanger on the Petro I unit. The replacement…...
OSHA opened an inspection of the mill on Dec. 27, 2016, in response to a complaint alleging unsafe working conditions. Inspectors discovered employees exposed to serious safety hazards, including permit-required confined space hazards and LOTO failures, which I have summarized below:… Membership Required You must be a member to access this content.View Membership LevelsAlready a...
Both OSHA’s and EPA’s process safety standards require operating procedures to contain the “steps required to correct or avoid deviation(s)”, but what exactly does this mean? I really wish OSHA/EPA would have phrased it as “avoid or correct” as putting the words in this order is actual reality. Let’s look at a simple process set-up…...
UPDATED 8/15/2017 with OSHA Case info: This has now been classified as a “Hot Gas Defrost Valving Error”. On September 11, 2012, Employee #1, a temporary employee was working as a racker-blender at the [wine company], was exposed to anhydrous ammonia, and died of asphyxia. Employee #1 was found in the west hallway 54 ft…...
FAQ Number: 1784 Date Published: August 04, 2017 Question: Does a facility have to count theft/diversion chemicals of interest in transportation packaging towards the screening threshold quantity if the packaging is on or attached to motive power to include overnight? Answer: Yes. 6 CFR Part 27.203(c) states that facilities must calculate theft/diversion chemicals of interest in transportation…...
Flaring took place over several days at a bulk propane plant after an unidentified third-party carrier, who is used to haul propane to the site, inadvertently offloaded anhydrous ammonia into propane storage tanks at the site. “It was a driver error on their end, and ultimately there was anhydrous that was in the storage tank…...
This week we learned of a lawsuit in KS regarding the location of a proposed (actually permitted) cold storage facility. Landowners near the facility have filed suit asking a judge to reverse the county commission’s approval of the 411,000 square feet cold-storage facility near their homes. Neighbors say the plan doesn’t provide the right setbacks or…...
This posting includes some very interesting citations issued by EPA (not OSHA). For example, EPA took issue with using “pink ribbons” on valves being used in an energy isolation for contractors installing a piece of equipment – rather than LOTO locks or tags! This “ribbon” idea is still fairly prevalent in the refrigeration industry still…...
