I was asked what I thought was the best flammable liquid code on the entire planet.  Honestly, I can not answer, as I do not know all the flammable liquid codes on the planet, only those I have worked with in the countries where I do process safety work.  But in my limited experience, I would say Ontario’s Ministry of Labour is one of my favorites as it requires some serious upgrades...

SAFTENG NOTES:  Interesting citations… GDC on “Opening process equipment” and GDC on LEL detector(s) locations 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,...

Respondent has an “All Other Basic Organic Chemical Manufacturing” process at the Facility, meeting the definition of “process” as defined by 40 C.F.R. § 68.3. Respondent has greater than a threshold quantity of Vinyl Acetate, Ethylene oxide, Ammonia, Methane, Propylene, Acetaldehyde, and a Flammable Mixture (” the Regulated Substances”) in a process at the Facility,...

Respondent is the owner and operator of the facility that produces anhydrous ammonia, urea fertilizer, and urea-ammonium nitrate which are loaded on trucks and railcars for distribution. The Respondent’s Facility chemical processes meet the definition of “process” and “covered process”, as defined by 40 C.F.R. § 68.3. The Respondent’s RMP program level 3 covered...

OSHA determined that an Arkansas construction contractor failed to test oxygen levels in the confined space before two workers entered a sewer 20 feet below ground at an Edmund work site and died because of a lack of oxygen.  The investigation into the June 14, 2022, incident found that an employee climbed into a newly installed sewer manhole to conduct testing when they lost consciousness. Trying...

Every year about this time, I take time to reflect on the year.  This year I had the privilege to spend 100% of my time with Union Pacific Railroad, but I stayed connected with many of you, and through our many late-night discussions, I am reminded that many businesses get blinded by all the tinsel on the Christmas tree.  We now have three major movements within our profession. I am a fan...

An ounce of PREVENTION is worth a pound of cure.   PREVENT   PROTECT     MITIGATE

Over my 30+ year career in safety and health, I have seen and participated in many “flavor of the month” initiatives.  Almost all of these were out desperately trying to achieve an OSHA rate.  I know; there’s a lot to unpack with that statement.  Probably the most significant movement of my career was the Behavior Based Safety movement in the 1990s and 2000s. ...

I am always amazed to hear people complain about the degree of our auditing.  Most clients hire us for detailed auditing, but some see the PSM/RMP 3-year audits as a “check-the-box” exercise and do not appreciate our auditing skills and experience (LOL).  Comments/Questions like… “Would OSHA really cite for that?” are commonplace.  Let me be clear; our job...

This topic can be hotly contested by some; why is beyond me.  Some businesses get lazy in their approach to process safety and convince themselves that flanged piping is cheaper (and easier) than joining the pipes using welding methods.  As we have discussed, welding our PRIMARY CONTAINMENT system, such as the piping, comes with many requirements to ensure we have the proper management system...

I can not think of a single business that operated and maintained a PSM/RMP-covered process that did not utilize LOCTITE®.  It is a beautiful product; however, it may be the most overused and abused product within the covered process.  When used PROPERLY and per Henkel’s instructions, the product works well.  But like most really good products, it eventually leads to misuse in...

This Instruction STD from MI-OSHA is too good not to share with those who deal with 1910.106(e) and their flammable liquids safety efforts.  It does a nice job comparing the 1910.106 (which is based on the 1968 edition of NFPA 30) with the current NFPA 30 standard. … HomeRead More »