The latest International Mechanical Code (IMC) has gotten more particular in how our exhaust systems get their make-up air.  510.5.5 Makeup air is a new section that clarifies what we have discussed in the “design basis” of our ventilation systems… (emphasis by me) … HomeRead More »

Another reason I like using the IFC over OSHA standards is that they take a lot of guesswork out of the safety equation!  Take, for example, the following list of 42 specific locations where a fire extinguisher is required based on the hazard… … HomeRead More »

For several editions, the IFC has incorporated a “Performance-Based Design Alternative” to comply with the requirements of Part V—Hazardous Materials (Chapters 50-67).  This was initially added so that facilities already doing PSM/RMP could show compliance with the state fire code without any additional work. In the 2021 edition of the IFC, this alternative has been expanded to include...

A video based on Don Merrell’s famous safety poem “I chose to look the other way” Don Merrell J.R. Simplot Company Don Plant Training Center … HomeRead More »

Image Source The infamous LPG Cylinder Exchange “Cage”.  Pull into any convenience mart/gas station these days and you will most likely see one of these cages.  I have always claimed that these cages require Vehicular Barrier Protection (VBP) where they are in the path of vehicles and I still stand behind my position.  But NFPA and the National Propane Gas Association...

Most adults have seen Sky Lanterns in movies, and some of you may have even participated in their release.  They are very popular at weddings, festivals, and memorials.  But these devices pose serious fire hazards and are being banned by many local Authorities Having Jurisdiction (AHJ).  They are essentially a paper hot air balloon with an open flame that drifts in the wind and eventually...

Respondent is the owner and/or operator of a facility that uses, handles, and/or stores more than a threshold quantity of ammonia (anhydrous), ammonia (concentration 20% or greater), and chlorine, which are regulated substances, as specified at 40 C.F.R. §§ 68.115 and 68.130. During the inspection, the EPA representative observed alleged violations of section 112(r) of the CAA, 42 U.S.C. § 7412(r),...

Respondent is an owner and operator of a petroleum refinery. Refining operations at the Facility are currently idled. EPA conducted an inspection of the Facility on September 20 – 26, 2022, to assess compliance with Section 112(r) of the CAA (the “Inspection”). During the Inspection, and in a letter dated October 13, 2022, EPA informed Respondent of observations made during the Inspection. EPA...

In FY 2022, the agency continued its efforts to reduce risks of accidental releases at industrial and chemical facilities, such as: Concluded three (3) judicial actions, 145 administrative penalty actions, and 18 administrative compliance orders In FY 2022, EPA renewed its presence in the field and increased its on-site inspections by more than 150% compared to FY 2021. EPA has addressed serious...

As we have discussed at length, OSHA is in the process of updating the HAZCOM Standard (1910.1200) to reflect GHS Rev. 7.  The most significant change in this adoption will be how Flammable Gases are categorized in 1910.1200 Appendix B, and this will also impact the PSM standard (1910.119) application.  Here is OSHA’s official justification for these changes: … HomeRead More...

The Respondent operates plastics material and resin manufacturing processes at the Facility that produces polymers used in various applications and products, meeting the definition of “process “, as defined by 40 C.F.R. § 68.3. The Respondent produces, processes, handles, and stores 1,3-Butadiene, Chlorine, Propylene oxide, and Acrylonitrile at the Facility. On February 2, 2022, an incident...

OSHA’s VPP efforts in process safety has offered the following questions regarding the PSM activities in the process.  Here are seven questions that will help you gauge your level of PSM expectations related to ammonia refrigeration: … HomeRead More »