The Cal/OSHA Process Safety Management Unit has cited a refinery and three contractors a combined $1,753,375 for serious safety violations following a confined space death of a 35-year-old worker who suffocated in a regenerator overflow well. Cal/OSHA inspectors cited three of the four employers with willful and serious violations after determining that they failed to follow confined space regulations,...

I am not sure who came up with this, but it is a classic example of far too many organizations. … HomeRead More »

As many of you know I have taken on a new client (full time) in 2022 and my role in this organization is to build a safety management system (SMS).  And let me tell you what, if you thought explaining a RAGAGEP to management was difficult – try explaining that safety is a “process” and an SMS should function just like a QA/QC process in a business.  I have written several...

The respondent is the owner and operator of a chemical manufacturing facility. EPA conducted an inspection of the Facility on May 1-4, 2018, to determine the Respondent’s compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. The following chemicals are “regulated substances” pursuant to 40 C.F.R. § 68.3. The threshold quantity for the regulated substances, as listed in...

Respondent owns and operates an ice-making plant that uses anhydrous ammonia in a refrigeration “process”. In 2016, Respondent filed a Program 3 RMP for the Process and reported that it used 22,000 pounds of anhydrous ammonia. In accordance with 40 C.F.R. § 68.10(a) and (f)-(h), the Respondent’s use, storage, and handling of anhydrous ammonia in the Process are subject to the requirements of RMP Program...

Respondent is a limited liability company that operates as a public warehousing facility.  The term “have a general duty in the same manner and to the same extent as section 654 of title 29 [of the U. S. Code]” means owners and operators must comply with the General Duty Clause in the same manner and to the same extent as employers must comply with the Occupational Safety and Health Act (“OSH...

I like to explain the documentation for our pressure vessels much in the same context as our birth certificates.  For every pressure vessel in service today, we must have that vessel’s U-1 Form.  And please don’t tell me about the OSHRC decision stating otherwise.  I really don’t care what a group of lawyers think about how I manage my process hazards.  In other...

We are working to implement a formal root cause and corrective action process for a client. The industry has a very different view and approach to what I have come to know over the last 30 years as Human Factors. I think my friends “down under” are reading my mind or my articles at SAFTENG these past couple of months. One of my favorite experts in HF has posted one of his best pieces of work on the...

As we approach The National Safety Stand-Down To Prevent Falls in Construction (May 2-6, 2022) I am reminded of how some view “Elimination” within the Hierarchy of Controls.  The number of postings on social media calling for the “Elimination of falls” in the construction industry has me asking… can this actually be done?  One such proposal calls for roofs to...

In the USA we use ASME Section VIII, Appendix M-5, and the National Board’s Part 4 when we need to install a block valve before or after a relief valve (RV).  In Saskatchewan, Canada their safety authority has a program titled “Pressure Relief Path Stop Valve Control Program“.  It is a really nice start to develop a “car seal program”.

These little safety devices cause such big troubles because of pure ignorance.  I continue to have silly debates with very smart people about meeting the absolute bare minimums from so many different recognized and generally accepted good engineering practices (RAGAGEPs).  As of today, I have written about Hydrostatic Relief Valves 84 times.  This week, I am back in my process safety...

On November 25, 2020, an explosion and fire occurred at an industrial facility in Houston BC. The facility utilizes a system incorporating a large natural gas-fired air heater to dry wood fiber material for the purpose of wood pellet production. The facility had recently been experiencing issues with operating conditions with the dryer system. The system was producing abnormal temperature spikes, irregular...