This is a topic I have written about several times before and EPA has made their position fairly clear in their RMP Q&A’s. SAFTENG members can CLICK HERE to read the summary of the EPA Q&A’s regarding railcars that are NOT attached to a mode of transport (i.e. locomotive). These railcars that sit out on…...
There are not many safety professionals who have been in the profession since the day OSHA came onto the scene that has not order and hung a safety sign or two. I personally believe keeping safety in the minds of the workers is a big part of keeping them safe. They have so many distractions…...
I teach around 20 HAZMAT courses each year for industrial response teams and fire departments and the differences in how these two groups conduct their DECON can be HUGE. Almost everyone who has been through a 24-hr or 40-hr HAZMAT course has seen a 6 stage DECON up to a 20 stage DECON; but are…...
MANY THANKS to my NEWEST and RENEWING Partners in Safety since 2006 since 2014 returning partner from 2012 2014 Fatality Tracker Electrical 8 (2013 = 32) (2012 = 68) Forklift/Manlift 9 (2013=62) (2012 = 52) Mining* 8 2013=87*) (2012 = 92*) *no longer includes China accidents Explosions 30 (2013=194) (2012 = 241)…...
Does your safety program have any safe work practices or does your Process Safety Management system have procedures with this requirement? It seems to be the fairly commonplace to require personnel to “have PPE available” for some critical tasks that can turn into an IDLH environment rather quickly. For those not familiar with this “practice”,…...
Inspect at least 4% of the total number of RMP-regulated facilities during FY 2014. Of these inspections, at least 36% should be conducted at high-risk RMP facilities, using the list derived from established high-risk criteria and provided by headquarters to regional offices at the beginning of the fiscal year. Regional program managers may, after consultation…...
The Risk Management Program (RMP) is implemented by the Office of Emergency Management (OEM) in EPA’s Office of Solid Waste and Emergency Response (OSWER). EPA and state and local implementing agencies conduct inspections at RMP facilities to determine compliance with RMP regulatory requirements, but because resources for conducting inspections are limited, within the past…...
This is an EXCELLENT presentation from EPA (4/2013) on doing RMP Inspections @ Ethanol Facilities. Although the presentation appears to be specifically for Ethanol facilities, it’s “suggestions and tips” WILL apply to any RMP covered facility (and for PSM-covered facilities as well). Some of the interesting revelations are: 1) EPA uses Google and Bing Satellite…...
This is why I have oh little faith in our government to protect us!!! Enforcement can NOT and should NOT be the driver behind improved environmental, health and safety performance! The hypocrisy in this report, aimed at the agency tasked with enforcing the very rule they wrote is nothing short of pathetic. Sitting here I…...
Does your process have any “underground piping”? We do not see this design in newer process designs, but in years past – putting pipe underground seemed like a good idea. This NTSB report does an excellent job of breaking down the failure modes of underground piping. The National Transportation Safety Board determined that the probable…...
An oldie but a goodie, showing how chlorine, with a VD>2.5 acts during a release (i.e. stays on the ground). On August 14, 2002, a chlorine transfer hose ruptured during a rail car (90 ton) unloading operation at a chlorine repackaging facility near Festus, Missouri. The hose rupture ultimately led to the release of 48,000…...
Another team of UNTRAINED, or TOTALLY IGNORANT but trained, workers doing their version of confined space entry. This is for those who provided negative comments on my other “entry photo”. This is good ole USA safety – NOT some third world country. And by the way, the workzone traffic management is a pathetic effort as…...
