Safety Info Posts

CFATs Program Statistics as of August 1, 2013

More than 44,000 preliminary assessments were reviewed by DHS from facilities with chemicals of interest 4,298 facilities are currently covered by CFATS More than 3,000 facilities voluntarily removed, reduced, or modified their holdings of chemicals of interest 1276 visits to assist facilities with compliance 589 Security Plans authorized 182 Security Plans approved following an onsite inspection…...

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How can I determine if my facility’s wastewater treatment operation meets the Chemical Facility Anti- Terrorism Standards (CFATS) exemption under 6 CFR 27.110(b) for the Federal Water Pollution Control Act?

Section 27.110(b) of 6 CFR exempts from CFATS “Treatment Works,” as defined in section 212 of the Federal Water Pollution Control Act, Pub. L. 92-500, as amended. If an industrial facility treats its wastewater and that water is directly discharged into a body of water without further treatment, then the facility must be registered with…...

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“It’s just Ammonia” – yep it sure is!

UPDATED 8/17/14 Routinely we hear the argument that Anhydrous Ammonia should not be on OSHA’s or EPA’s chemical lists for PSM/RMP inclusion.  Like most industries that use a single highly hazardous chemical as a “utility” in their process(es) v.s. manufacturing the HHC or using the HHC in the manufacturing process, these industries feel “their chemical”…...

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EPA RMP citations @ Manufacturing Plant (NH3 & $146K)

Respondent owns and operates a manufacturing facility, which produced, used, or stored more than 10,000 pounds of anhydrous ammonia. During an October and December 2011 inspection EPA found the following issues, settling for $146,000…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Executive Order – Improving Chemical Facility Safety and Security

The White House, Office of the Press Secretary For Immediate Release August 01, 2013 EXECUTIVE ORDER – IMPROVING CHEMICAL FACILITY SAFETY AND SECURITY By the authority vested in me as President by the Constitution and the laws of the United States of America, it is hereby ordered as follows:    Section 1. Purpose. Chemicals, and the facilities…...

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Passivation… PSM/RMP activity that belongs in the “initial start-up” SOP?

A common situation we find is that facilities struggle to understand how their “initial start-up” procedure for a new piece of process equipment can/will differ from their other start-up procedures for the equipment (e.g. normal, after a turnaround, after an emergency shutdown, etc.). Recently I have learned of a process used on galvanized condenser coils/tubes that…...

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OSHA/NIOSH Hazard Alert – 1-Bromopropane (1-BP)

1-Bromopropane (1-BP) is a solvent that is used in degreasing, dry cleaning, spray adhesives, and aerosol solvents. Occupational exposure to 1-BP has been linked to neurological illnesses. Animal studies show that 1-BP may also cause cancer and reproductive disorders. Controls and personal protective equipment are available to protect workers from 1-BP exposure.  CLICK HERE (pdf)…...

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Making the case my PSM/RMP covered process complies with RAGAGEPs (Piping)

There is one small little sentence in 1910.119 (as well as Part 68) that is causing all kinds of heartburn. I like to call this requirement the “General Duty Clause” of process safety. To fully understand what this requirement entails we first have to understand what is meant by a standard being a “performance oriented”…...

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