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Hazard ID is fundamental to any SMS and an ALJ who gets it

Sometimes a lawyer or set of lawyers can surprise us… This is a quote from a recent OSHRC ALJ decision, regarding the employer’s responsibility to conduct inspections of the workplace to identify and correct hazards: “As an employer, Respondent is obligated to provide safe working conditions and ensure safe work practices. Implicit in that obligation…...

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RESPECT the Cl2

At approximately 9:45 p.m. on November 4, 2003, a maintenance employee went to the chlorine house to turn on the chlorination system. The chlorine house measured 3 feet, 10-inches wide by 5 feet, 10-inches long and was approximately 10-feet high. The water lines ran through a hole in the block wall. The hole in the…...

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Example of “Short-Threading”

One of the things I look for in my PSSR walk downs is “short-threading”. I was raised with the old pipe-fitters rule of “three threads showing”; however, ASME now accepts “full engagement” as bolt flush with nut. Some companies will have a QA/QC requirement of 1-thread showing. So I have to accept the ASME definition…...

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Leak Testing per ASME Section V, Article 10 – Leak Testing

I see many contractors still attempting to argue that Pressure Testing and Leak Testing are the same tests. This is incorrect, as I have often discussed in my ramblings on this website. This post breaks down the requirements of the most common “leak test,” called the “bubble test.” ASME B31.3 refers us to ASME BPVC,…...

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LNG Hose Failure during Ship-to-Ship Transfer (Video)

This video is an excellent visual of the expansion ratio of Liquified Natural Gas. During a transfer, a ship broke free and stretched the hose until it broke. It was all captured on cellphone video…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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6,000 pound NH3 release leads to $169K EPCRA/CERCLA citations

The respondent was an owner or operator of the ice manufacturing facility where anhydrous ammonia is used in the manufacturing of ice. Anhydrous ammonia, CAS #7664-41-7, has a reportable quantity of 100 pounds, as indicated in 40 C.F.R. Part 355, Appendix A. On July 27, 2023, at or about 4:34 a.m. CDT, a release of…...

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Hazards of evacuating NH3 from the process

On February 7, 2017, an employee, 50, was making preparations to replace the relief valve of a 1,000-gallon ammonia (NH3) tank. The incident investigation reported that the tank was empty of liquid NH3. However, it contained approximately 80 psi of vapor pressure. The employee set up a 30-gallon drum that contained water and affixed it…...

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OSHA cites employer for doing pneumatic pressure testing rather than hydrostatic pressure testing (5A1 – Fatality)

On July 14, 2009, Employees #1 and #2 were performing a pneumatic test to verify leak tightness of a new pipeline meter station. The test medium was nitrogen gas, and the system being tested included piping and two (2) pressure vessels. Numerous leaks were found in the system during the test. The system reached the…...

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Filling ungrounded process vessel with Isopropyl Alcohol (Flash Fire)

On July 23, 2020, an employee, 30, was looking into a vessel being filled with chemicals, including Isopropyl alcohol, to ensure the level of the mixture was above the blades before turning on the mixers. The access port was mounted with one bolt so the employee could rotate the cover to look in. The employee…...

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Buyer Beware… Not all Flammable Cabinets are created equal!

In 2025, one would hope we would be beyond these failures. But when the price is more critical than UL/FM approval or even an attempt to comply with Fire Codes and OSHA, we will inevitably end with a chuck of metal rather than a functioning flammable liquids storage cabinet. See if you can spot the…...

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Management Oversight and Risk Tree (MORT)

MORT was first developed in the USA to analyze the root causes and causal factors for incidents in the nuclear power and aviation industries, but it has now been applied in many industries. However, it seems to be a “lost art” these days! MORT is a pre-populated tree based on a model of an organization’s…...

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