On August 12, 2016, hot work was being conducted by a contractor at a crude oil terminal on a section of pipe that contained residual crude oil. Using an isolation device, the pipe segment was plugged on both ends by a sub-contractor (hired by the primary contractor). During the welding operation on the inside surface of a flange, vapor inside the pipe gathered between two of the installed isolation...

Safety is a privilege to protect our teams. But you better F’ing respect that privilege and honor it. There is no higher calling than what we get to do day in and day out. If this is a job for you – get the hell out of our way and find something else to spend your time doing. This is a passion to most of us – sure, we get paid, we have families to care for. But we do this because we CARE...

OSHA has an actual policy of “Corporate Name Shaming.”  It is a horrible practice and harms OSHA’s credibility, as all “shaming” programs do.  But they continue it as if it makes a difference.  What amazes me is that some companies still do the same thing to their employees.  As the title of this article makes clear…  the FIRST and possibly...

A traditional view of events and accidents is that they are caused by human competence, attention, or attitude shortcomings. It may be under the label of “loss of situation awareness,” “procedural violation,” or “poor management”. A new and different view is that human error is NOT the cause of failure but a SYMPTOM OF FAILURE – trouble deeper inside the system. Human error is not...

Recently, several fires occurring during hot work have been reported to BSEE. Hot work is any job with the potential to create an ignition source, such as an open flame, sparks, or high temperatures. Examples of hot work include welding, using acetylene torches, and grinding and cutting metal. … HomeRead More »

Bureau of Safety and Environmental Enforcement field personnel have indicated a need for increased operator awareness when using temporary equipment (TE). Some TE may be a potential ignition source and can range from small items such as portable welding sets to large skid-mounted packages (e.g., temporary generators, air compressors, hydraulic power packs, well-testing equipment, process equipment,...

In my discussions with SAFTENG members who are Process Safety clients, the question is always asked:  “Where do you get the terms “responding facilities” and “Non-Responding facilities” from?  These are terms used in EPA’s Risk Management Plan rule, and I have said many times in my writings that not every facility is required to have an emergency response...

Respondent has a synthetic rubber manufacturing process at the facility that processes two petrochemicals, butadiene and styrene, and the temperature of the reaction is controlled by anhydrous ammonia. Respondent has greater than a threshold quantity of 1, 3-Butadiene and Ammonia (anhydrous) in a process at the Facility, meeting the “covered process” definition defined by 40 C.F.R. § 68.3. Complainant...

Respondent is the current operator of a chemical manufacturing and distribution facilities. The General Duty Clause applies to any stationary source producing, processing, handling, or storing regulated substances, as defined above, or other extremely hazardous substances (“EHS”). EHSs include regulated substances listed pursuant to Section 112(r)(3) of the Act at 40 C.F.R. § 68.130 and chemicals on...

The requirement to issue a hot work permit, including documentation of necessary fire protection and prevention measures, is currently in the RMP regulation only for Program 3 processes. Under 40 CFR 68.85(b), “The permit shall be kept on file until completion of the hot work operations.” Under the existing RMP regulations, it can be difficult for implementing agencies to determine if the facility...

EPA initially looks to the latest version of industry codes, standards, and guidelines to determine whether an owner or operator has documented compliance with RAGAGEP under 40 CFR 68.65(d)(2), given that 40 CFR part 68 does not define the phrase “recognized and generally accepted good engineering practices.” EPA believes this application makes sense because the plain meaning of the phrase is that...

The current definition of “retail facility” at 40 CFR 68.3 is “a stationary source at which more than one-half of the income is obtained from direct sales to end users or at which more than one-half of the fuel sold, by volume, is sold through a cylinder exchange program.” The period of sales to end users is unclear; it lacks a definite time frame to calculate whether more than one-half of the facility’s...