OSHA’s PRCS standard defines the terms Blinding and Blanking in the same definition, but there is actually a difference between these practices.  Here is OSHA’s definition: Blanking or blinding means the absolute closure of a pipe, line, or duct by the fastening of a solid plate (such as a spectacle blind or a skillet blind) that completely covers the bore and that is capable of withstanding...

As my time in the railroad industry comes to an end, I broke the ice with the FRA through some close friends in DOT/PHMSA to understand why/how the railroads are 50 years behind the times in how safety is managed.  Through our many and lengthy discussions (many thanks to E.J. and others), I received a “White Paper” on a study that the FRA did after the 2005 Graniteville, SC accident...

  The rupture of the V-1 vessel appears to have caused a boiling liquid expanding vapor explosion (BLEVE, pronounced ‘blev-ē). A BLEVE is the “sudden loss of containment of a pressure-liquefied gas existing above its normal atmospheric boiling point at the moment of its failure, which results in rapidly expanding vapor and flashing liquid. The release of energy from these processes (expanding...

The City of New Orleans Office of Inspector General (OIG) conducted a performance audit of the City of New Orleans’ (City) Department of Safety andPermits (S&P). The objective of the audit was to determine if S&P inspectors (City inspectors) conducted their inspections in accordance with S&P policies and procedures. The scope of the audit was all building, mechanical and electrical permit...

Updated on 11/1/22   Effective Date: October 22, 2022 This rule created a new chapter, refinery worker training and certification in high-hazard facilities, implementing the advanced safety training requirements under chapter 49.80 RCW, adopted by the Washington State legislature in 2019. Chapter 49.80 RCW, requires owners of petroleum refining or petrochemical manufacturing facilities to use...

New York City’s Community Right-to-Know Law (Local Law 92) requires facilities where extremely hazardous substances or regulated toxic substances are present at or above federally determined levels (Threshold Planning Quantity), to prepare and submit a Risk Management Plan to the Department of Environmental Protection on or before March first of every year. In situations where a substance is...

We have recently heard the phrase “inherent safety” used by OSHA and EPA as both agencies work at revising/updating their process safety standards.  But what exactly is “inherent safety,” and why is it at the top of the Hierarchy of Controls for process safety? Inherently safer practices are an approach to designing safer chemical plants, chemical processes, and storage...

A manufacturing company that works with dangerous chemicals faces $192,620 in fines for 46 serious and 17 general safety and health violations. The facility formulates products for agricultural fertilizer, airports, pulp and paper, and water treatment.  Washington State Department of Labor & Industries (L&I) inspectors found 13 violations relating to confined space entry rules due to workers...

If you have ever taught a LOTO course, you know that you will always get the questions… “Is ___ psi a hazardous energy source?”.  Regardless of the gas’s inherent hazard(s), we should always answer by saying “Zero = Zero,” and in LOTO, we are required to achieve a zero energy state.  So, any psi of a gas is a form of energy; trying to define it as non-hazardous...

Pay close attention to the break in the smoke plumes on the right hand side of the screen… Today, the U.S. Chemical Safety and Hazard Investigation Board (CSB) released its final investigative report into a massive fire and explosions at the Philadelphia Energy Solutions (PES) Refinery in Philadelphia, Pennsylvania, that occurred in June 2019. The incident occurred when a corroded pipe elbow...

Respondent owns and operates an ice manufacturing facility that typically operates 24 hours a day, seven days a week. On June 26, 2019, EPA performed an inspection of the Facility pursuant to Section 112(r) of the CAA, Sections 304-312 of the Emergency Planning and Community Right-to-Know Act (“EPCRA”), and Section 103 of the Comprehensive Environmental Response, Compensation, and Liability....

Many organizations have become very good at identifying the ACTIVE failures associated with an accident; however, in almost all of the accident investigations I have been involved with, I find LATENT failures to play a bigger role than active failures.  But that is a really hard pill for most organizations to swallow.  But there is a tool within our process safety management system that is...