Respondent is the owner and operator of a frozen foods processing facility that includes anhydrous ammonia storage tanks, valves, piping, compressors, freezer tunnels, and other buildings, structures, equipment, installations, or substance-emitting stationary activities from which an accidental release of anhydrous ammonia may occur; which belong to the same industrial group; which are located on one...

As one of my favorite authors said in his book “Risk Makes Sense”… Remember that the biggest danger in risk assessment is not the threat itself but the mind space of the person who overlooks, underestimates, ignores, or is perhaps deluded in their assessment of that risk.Dr. Robert Long, Risk Makes Sense If you have not already done so, purchase this book!  Dr. Long offers a...

The three C’s of Behaviors In full disclosure, I am not a behavior specialist or a psychologist, just a safety professional who has spent the last 30+ years studying human behaviors. This 3-C model attempts to demonstrate how workers go from the CONCERNED state, the first of the C’s, to the CONFIDENT state, the last of the C’s. I have no scientific studies to validate my model, but...

This video is making the rounds today. As far as I know, it is real, but those of you who are TRAINED responders will be doubtful an actual response could be done so poorly. I have no idea what is/was inside the cylinder, which they carried by hand to an awaiting pickup truck (let’s pray it was not a flammable gas and the truck was left running or that it was not a toxic gas and the driver was...

The Director of the Michigan Department of Labor and Economic Opportunity announces the amendment of the following rules: GI Part 74. Firefighting – MIOSHA has amended General Industry Safety and Health Standard Part 74. Fire Fighting. Public Act 291 of 1966, The Fire Fighters Training Council Act, was amended in 2020. Due to this amendment, the Bureau of Fire Services suggested that MIOSHA review...

The regulation governing the reporting of accidental releases can be found in title 40 Code of Federal Regulations (CFR) Part 1604, Reporting of Accidental Releases. The regulation requires the owner or operator of a stationary source to report any accidental release resulting in a fatality, serious injury, or substantial property damage​s. The purpose of this part is to require prompt notification...

Massachusetts Fire Code hazardous material processing regulation (527 CMR 33)  requires a hazard evaluation or limited process safety program for many companies that have never faced this requirement before, (though many companies have been essentially performing these tasks as good practice).  Many companies covered by this regulation must now document that a hazard evaluation has been done,...

This past week we witnessed a tragic incident involving chlorine (Cl2), a 25-ton ISO container, and a crane/sling failure.  The incident claimed 13 workers’ lives and sent another 250 to hospitals for emergency care.  Many have claimed this to be the “worst-possible outcome”.  Here in the USA, we call these “Worst Case Release Scenarios” (WCS).  A lot...

The Respondent manufactures bread and bakery products. The Respondent’s bakery processes meet the definition of”process” and “covered process “, as defined by 40 C.F.R. § 68.3. The Respondent had one RMP program level 3 covered process (anhydrous ammonia refrigeration system) which stores or otherwise uses a regulated substance in an amount exceeding the applicable threshold....

Respondent has a commercial scale distillation process used for research purposes at the Facility, meeting the definition of “process “, as defined by 40 C.F.R. § 68.3. Isobutane is a “regulated substance ” pursuant to 40 C.F.R. § 68.3 with a threshold quantity of 10,000 pounds.  Respondent has greater than a threshold quantity of isobutane, in a process at the Facility,...

World-class safety can be summed up in this manner… The ability to recognize a serious hazard that can be controlled by an existing safe work practice that is in place for complying with a different OSHA standard.  If you’re a process safety engineer/practitioner you have dealt with “line break/process opening” for your Highly Hazardous Chemicals (HHC) and Extremely Hazardous...

As we saw in Jordan last week, gases stored as liquids can “auto-refrigerate” in large-scale accelerated releases.  In the aftermath pictures, we can see a clear frost line along the bottom of the ISO container, which is evidence of a refrigerated liquid level within the container. (See pic and explanation below) … HomeRead More »