Currently, under 40 CFR 68.3, the term “stationary source” does NOT apply to transportation activities, including storage incident to transportation for any regulated substance or any other extremely hazardous substance.  A stationary source does include transportation containers connected to loading/unloading equipment or used for storage, not incident to transportation. Still, the term “storage,...

The new criteria include violations of all hazards and OSHA standards and will continue to focus on repeat offenders in all industries. Previously, an employer could be in the program for failing to meet a limited number of standards. The changes will broaden the program’s scope with the possibility that additional industries will fall within its parameters.  Specifically, the updated criteria...

A 48-year-old worker entered a tanker trailer to inspect it as part of an annual U.S. Department of Transportation requirement and was overcome by exposure to bleach and chlorine gas. The worker was found unconscious in the tanker trailer, and he later died of his injuries. An investigation by OSHA determined his employer failed to identify and evaluate atmospheric hazards in the confined space, train...

The respondent’s facility (“Facility”) is located in a mixed-use area. The Facility is located on the third and fourth floors of a mixed-use commercial/industrial building that houses medical offices, a deli, and other businesses. The Facility is located within a third of a mile of several tourist attractions, including museums and restaurants. The east end of the building abuts the...

Another great review on the design, construction, and capacity of flammable storage cabinets, a topic that seems never to go away. Safety Tip: Single-walled supply cabinets do not work. … HomeRead More »

Why GAO Did This Study? Over 11,000 RMP facilities across the nation have extremely hazardous chemicals in amounts that could harm people, property, or the environment if accidentally released. Risks to these facilities include those posed by natural hazards, which may damage the facilities and potentially release the chemicals into surrounding communities. Climate change mayAccording to the Fourth...

Ammonia (CAS# 7664-41-7) is an Extremely Hazardous Substance (EHS), listed at 40 CFR Part 355 Appendix A  EPA website and Appendix B with a reportable quantity (RQ) of 100 lbs. Both ammonia and ammonium hydroxide (CAS# 1336-21-6) are listed as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substances at 40 CFR 302.4. Under CERCLA, ammonia is listed with...

The RMP Amendments, finalized on January 13, 2017, included a requirement for owners or operators of a stationary source to engage in emergency response coordination activities (40 CFR §68.93). The regulatory text in 40 CFR §68.10(b) states that compliance with these activities must be completed by March 14, 2018. Because the RMP Amendments were not effective until September 21, 2018, are facilities...

I want to share a perfect failure scenario that happened to me and has been happening to me since April 2021. And yes, I see the world through the lens of a safety engineer – hate me for it if you must.  The failure is 99% my fault for trusting a simple financial tool via my AMEX credit card.  This morning Becky alerted me to a repeated charge on my card for $8.61.  It was for...

Most formally educated or well-trained safety professionals are familiar with the Hierarchy of Controls.  We use this approach daily in our work to reduce the likelihood of an event and/or the event’s severity.  Mr. Kletz always had a different take on using this philosophy in process safety and as always – he nailed it! … HomeRead More »

Respondent has an Ethanolamines unit used for chemical manufacturing purposes at the Facility that has greater than a threshold quantity of anhydrous ammonia.  EPA Findings of Violation Count 1 – Quality Assurance … HomeRead More »

At 9:00 a.m. on January 31, 2022, an employee who worked as a General Laborer fo r an Industrial Nursery was filling propane cylinders from a bulk propane tank. As the employee was finishing filling a cylinder, he began to remove the filling hose before shutting off the propane. As a result, the gas escaped and caused freezing burns to the employee’s hands, requiring hospitalization. …...