Respondent manufactures a range of specialty surfactants for use predominantly in the oil and gas industry. The process of ethoxylation involves reacting ethylene oxide with various common chemicals, such as fatty alcohols and phenols, to produce a variety of products. The plant can also use propylene oxide instead of (or as well as) ethylene oxide in a similar process known as “propoxylation.”...

This is from an EPA Multimedia inspection that looked at a chemical process that was below the TQ, so they used the RMP GDC to inspect.  What they found in the flammable process was that… … several of the facility’s components were made of aluminum. One condenser was installed with malleable iron tubes instead of stainless steel. Because of this, iron was being leached from the tubes...

Three (3) fundamentals are behind the “electrical classification” model for hazardous locations.  These three fundamentals mirror our approach to other workplace hazards, and understanding these three fundamentals will help make a lot of sense out of NFPA 497/499 and 1910.307. … HomeRead More »

The US still uses the Class and Division system to classify electrical systems in hazardous locations.  However, outside the US, the Zone system is more widely used.  Manufacturers are beginning to list their equipment based on the Zone(s) it is rated for, which can cause translation confusion.  The table below may be of help. … HomeRead More »

I have mentioned this fundamental HF design need in several of my postings.  CONSISTENCY is key in helping reduce human error.  I like to use STOP signs as my example.  But here are some fundamental principles when analyzing computer screens, workplace signs, etc., when it comes to COLORS… … HomeRead More »

We can learn a lot from Aviation Safety!  I came across this 2017 presentation on Runway Safety Trends and Runway Incursion Analysis and just loved how they analyzed their data to identify the trends, causes, and contributing factors.  Some of the data may be alarming, but that is not my intent.  This is how we should be analyzing our data in industrial safety. It really drives home...

I have spent much time reading NTSB accident reports over my career.  They are usually very educational, even for those of us outside the aviation industry.  This incident involving this mother of three being sucked into a jet engine has captured a lot of headlines due to its graphic nature, but there will be so much to learn from this incident in the coming months/years.  So far what...

I have several clients who offload ships/containers in this manner. Whenever I see this, I immediately go to “that is a PRCS”. The ship/container is for sure a CS, and the fact that we have an engine putting off CO inside the ship/container makes the space a PRCS. I am fortunate enough to have great clients who think about it and have agreed there is a risk in practice. But last month,...

Yesterday, OSHA announced its plans to promulgate a revised Process Safety Management (PSM) standard and a NEW Emergency Response Standard in 2023. Executive Order 12866 requires the semiannual publication of an agenda of regulations listing all the regulations the Department of Labor expects to have under active consideration for promulgation, proposal, or review during the coming one-year period....

The OSHRC has vacated four (4) heat-related OSHA citations against the United States Post Office.  This decision was based ON LEGAL matters regarding the Feasibility of Abatement of the Hazard.  ALL parties agreed to the fact that HEAT CAN BE A HAZARD, but when OSHA issues a GDC Citation, it must provide feasible abatement measures.  The ALJ and OSHRC agreed that the abatement measures...

Most adults have used an Automated Teller Machine (ATM) card in their lifetime.  But these machines, as high-tech as we imagined they were back in the day, had a design flaw that caused a lot of users a lot of trouble.  Human Error Problem:  ATM users would insert their cards, request cash, take it, and walk away, leaving their cards behind. Solution: a “forcing function”...

The derailment in East Palestine, OH, was a classic need for a Vent & Burn operation (as shown in the video).  There was some indication that one or more of the Vinyl Chloride railcars had begun its polymerization reaction, which could result in catastrophic consequences for many people and property.  This indication also eliminates the option of transferring the VCM to other containers. ...