Safety Info Posts

EPA explains the new Incident Investigation provisions in their Final RMP Amendments

EPA issued a letter explaining what incident investigations and root cause Analysis requirement changed from the proposed to final rule and what the final rule requires with regards to incident investigations.  Here’s what EPA said:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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EPA explains Safer Technology and Alternatives Analysis (STAA)

“Safer Technology And Alternatives” (STAA) refer to risk reduction strategies developed using a hierarchy of controls that are considered inherent, passive, active, and procedural. This strategy can be applied initially to all design phases and then continuously throughout a process’s life cycle. STAA includes concepts known as inherently safer technologies (IST) or inherently safer design…...

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EPA explains the new RMP rule Third Party Audit requirements

EPA has issued two letters that better clarify what the “Third Party Audit” requirements changed from the proposed to final rule and what the third-party audit requirements actually are.  Here’s what EPA said:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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EPA issues two (2) letters regarding Ammonium Nitrate

EPA issues “letters” on their website that helps clarify many of their rule requirements, much like OSHA’s Letters of Interpretation.  This week OSHA issued twenty-one (21) such letters following their FINAL amendments to their Risk Management Plan rule.  These two (2) letters address what EPA has done to further the safe storage and handling of Ammonium…...

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U.S. Court of Appeals for the Fifth Circuit agrees that a control room’s positive pressurization unit (PPU) is part of a “covered process” (PSM)

OSHA cited a refinery in 2008 for failing to inspect a piece of equipment known as the positive pressurization unit (PPU). The refinery contends that this citation is unlawful because the PPU is not encompassed by the relevant regulations. Because this dispute involves the interpretation of a binding regulation promulgated by the agency, we defer…...

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U.S. Court of Appeals for the Fifth Circuit finds that OSHA can’t cite for violations that were over 6 months old (PSM)

Delek purchased an oil refinery located in Tyler, Texas from Crown Central and took possession on April 29, 2005. Beginning in February 2008, OSHA conducted a four-month inspection of the refinery and issued a citation on August 18, 2008, finding violations of 29 C.F.R. § 1910.119 and other regulations that are not at issue here…....

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Safeguarding our piping (ASME B31.3, Appendix F)

Safeguarding is the provision of protective measures to minimize the risk of accidental damage to the piping or the harmful consequences of possible piping failure.  In most instances, the safeguarding inherent in the facility (the piping, the plant layout, and its operating practices) is sufficient without the need for additional safeguarding.  In some instances, however,…...

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Flanges and their joinment integrity

Three distinct elements of a flanged joint must act together to provide a leak-free joint: the flanges, the gasket, and the bolting Factors that affect performance include the following:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Changes to the 2015 IFC impact “Mechanical Refrigeration” requirements in a BIG WAY

The revisions to 2015 IFC, Section 606.12 clarify the code requirements and add references to two (2) International Institute of Ammonia Refrigeration (IIAR) standards and one American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc. (ASHRAE) standard for design and operation of ammonia refrigeration systems.  This edition of the IFC also pulls in a lot…...

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2016 Photo of the Week #52 (Newly NEMA rated switch – NOT)

Can you spot the hazard/code violation?  This is at a fueling station for work trucks at a facility.  This facility has many HAZLOCs so in general, “they should have known better”; but this is what happens when you contract out maintenance to unqualified and untrained contractors.  Work Order said… “Switch at gas pump not working”,…...

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2016 Video of the Week #52 (Scaffolding Collapse)

On Wednesday, surveillance footage captured the moment that a 10-meter-high section of scaffolding, which was carrying three workers, suddenly toppled down in Mianyang city in southwest China’s Sichuan Province.  Seconds after the collapse, some passersby ran to the scene to rescue the workers trapped underneath. More than 20 people eventually joined in to help with…...

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