Safety Info Posts

Does OSHA require introduction of fresh air for flammable liquid handling areas? (1910.106(e)(2)(iii)

/ Flammable Liquids /

OSHA’s says No; 1910.106(e)(2)(iii) does NOT require the exclusive use of fresh air for ventilation purposes.  OSHA states that 1910.106(e)(2)(iii) is a performance requirement and does NOT explicitly require the introduction of fresh air to meet the performance requirements of the OSHA standard. OSHA, under §1910.106(e)(2)(iii), expects employers to provide adequate ventilation to maintain concentrations…...

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Process Safety is more than a highly hazardous chemical (HHC) and its threshold

/ Chemical Process Safety (PSM/RMP) /

We are no longer surprised when we come across a “process” which is not a PSM-covered process because the facility has managed the quantity of their HHC below OSHA’s threshold. However, from a risk perspective, having 9,975 pounds of an HHC versus having 10,000 pounds does not lessen our process or personnel risks, but that…...

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EPA RMP General Duty Clause citations @ food plant (NH3 & $30K)

/ PSM and RMP Citations/Analysis /

Respondent produces meat and protein products for sale by third-party customers. As part of this process, Respondent uses anhydrous ammonia in a chill tank to prepare and preserve the products. Ammonia is a regulated substance listed in Table 1 to 40 CFR § 68.130. On the evening of January 15, 2016, after the Facility had…...

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How many flammable liquid storage cabinets can be in the same area?

/ Flammable Liquids /

One of the top questions we get when working with clients whose primary business is storing, handling, and processing flammable liquids is… How many flammable storage cabinets can we have in the same area? This answer used to be easy, but these days – not so much.  Back in the day, NFPA 30 (2000 Edition)…...

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OSHA clarifies Flammable Liquid Cabinet storage limitations (1910.106(d)(3)(i)

/ Flammable Liquids /

In 2011 someone wrote to OSHA and specifically asked for clarification on the use of the words “or” and “nor” in the paragraph Design, Construction, and Capacity of Storage Cabinets-Maximum Capacity, 1910.106(d)(3)(i), which states: “Not more than 60 gallons of Class I or Class II liquids, nor more than 120 gallons of Class III liquids…...

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Just how dangerous is NH3?

/ Chemical Process Safety (PSM/RMP), Emergency Response, Hazardous Materials, Respiratory Protection /

In my Process Safety, HAZMAT, and Emergency Response course, I always walk the students through an exercise to demonstrate just how dangerous chemicals such as Cl2 and NH3 are. So many have come to believe that these chemicals are hazardous only when we exceed the OSHA/EPA Thresholds for PSM/RMP. In a 40 ft × 40…...

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Just how dangerous is Cl2?

/ Chemical Process Safety (PSM/RMP), Emergency Response, Hazardous Materials /

In my Process Safety, HAZMAT, and Emergency Response course, I always walk the students through an exercise to demonstrate just how dangerous chemicals such as Cl2 and NH3 are. So many have come to think that these chemicals are only hazardous when we exceed the OSHA/EPA Thresholds for PSM/RMP. In a space that is 40…...

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A breakdown of the Atlas Foundry LPG BLEVE (2007)

/ Hazardous Materials /

Anyone who has taken one of my HAZMAT or Process Safety training courses has heard about and seen video of the Atlas Foundry LPG BLEVE that occurred back in 2007.  But in a recent process safety course, several students (volunteer FF’s outside of their full time job at this PSM facility) debated on the facts…...

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EPA RMP citations @ chemical plant (Flammables & $70K, w/ $80K SEP)

/ PSM and RMP Citations/Analysis /

Respondent’s facility contains a process that produces ethylene, propylene, benzene, butadiene, and toluene. Respondent’s facility has toxic and flammable regulated substances in a process in excess of the threshold quantities listed in 40 C.F.R. § 68.130. An EPA inspector conducted an inspection of Respondent’s facility on November 18-20, 2014. Following the inspection and a review…...

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EPA RMP citations @ chemical manufacturing facility (NH3 & $37K)

/ PSM and RMP Citations/Analysis /

Respondent owned and operated a chemical manufacturing facility that manufactures nitrogenous fertilizer. The facility processes natural gas to produce anhydrous ammonia. Anhydrous ammonia is the only regulated substance present at the facility and is used in the following processes or areas of the process: ammonia manufacturing, ammonia storage and loading, nitric acid (56%) manufacturing, nitdc…...

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