Safety Info Posts

Hydrostatic Relief done RIGHT!

Recently I had the pleasure of working with a team of engineers and EHS professionals on a PHA project for an Anhydrous Ammonia process. For those who may not know, hydrostatic relief valves are required on Anhydrous Ammonia processes, that are NOT associated with mechanical refrigeration, and unfortunately, there is little guidance on their design…...

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A review of OSHA’s “Shaming Campaign”

NOTE: a reduction in penalty can come about many different ways, so a reduction in penalty does not imply that the hazardous condition did not exist at the time of the inspection.  Many reductions in penalties occur due to negotiations requiring abatement of the hazard and extra’s like training supervisors in OSHA 10-hr course.   …...

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“Safety” for Process Safety Managers

There has been some mild interest in this course, with some inquiries about doing “special session” at a facility.  Typically these courses are taught for a facility/business and the topics can be revised based on the facility’s need(s).  This is NOT an OSHA 10-hour or 30-hour course and I do NOT issue certificates for these…...

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EPA RMP citations @ gelatin production facility (NH3 & $23K)

Information collected during the September 14, 2016 inspection of Respondent’s Facility revealed that Respondent failed to develop and implement a risk management program that complied with the requirements of 40 C.F.R. Part 68. EPA alleges that Respondent has violated the CAA and federal regulations promulgated pursuant to the CAA as follows: Count 1 Respondent failed…...

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EPA RMP General Duty citations @ commercial refrigeration facility (NH3 & $54K)

Respondent is the owner and operator or a commercial refrigeration facility that utilizes compressed anhydrous ammonia as the refrigerant. On or about January 28-29, 2015, EPA conducted an inspection at, and obtained information regarding the facility’s compliance with Sections 112(r)(1) and (7) of the CAA and the implementing regulations at 40 C.F.R. Part 68. Preliminary…...

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“Nonincendive Equipment” protection technique can be difficult to manage

In the world of Process Safety Management and processes containing flammable liquids and gases, the management of hazardous locations (HAZLOC) can be very difficult to manage; especially when a facility decides that some of their “Nonincendive” devices are acceptable.  The use of “Nonincendive Equipment” is one (1) of the twelve (12) acceptable “protection techniques” offered by NFPA…...

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Corrosion Under Insulation (CUI) (Video)

I have always wanted to get a working example of what goes on behind piping insulation once the vapor barrier has been compromised.   This video is one from a recent inspection and just happens to be in an NH3 refrigeration process, but this issue is found in any process where the temp of the…...

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Difference between Emergency Planning in a Public Fire Department and Private Response Group

I like to start out my 8-hr Emergency Management course with an exercise that demonstrates the vast differences in how a public FD plans for emergencies and how an industrial business should be planning.  Many do not realize the vast differences in how these two entities differ when it comes to emergency planning and response…....

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CAL OSHA Standards Board passes new PSM requirements for Refineries

The Department of Industrial Relations’ (DIR) Occupational Safety and Health Standards Board today approved a landmark regulation to strengthen workplace safety and health at oil refineries across the state. The new regulation provides a framework for anticipating, preventing and responding to hazards at refineries.  The approved regulation introduces a new refinery safety order enforced by…...

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