As a follow-up to my 2014 post, Are you maintaining your LEVEL A suits “by the book”? , where I covered the care/testing requirements for my brand of LEVEL A suits, I wanted to make sure the word is out… ALL LEVEL A suits built to ASTM F1461-17 REQUIRE some specific testing and inspection in order to be used for their full intended life span.  Failure to meet these inspections/testing...

At 12:30 am on May 30th, 2020, failure of a 6” pressure piping elbow located on top of a storage tank resulted in black liquor being sprayed onto adjacent buildings, equipment, and ground within an approximately 50m (165′) area. The line from the liquor transfer pump into the top of the tank failed and 74% black liquor solids were released for approximately 20 minutes. A similar failure had occurred...

To reduce the risk of more than 300 chemicals of interest (COI) being weaponized, the Cybersecurity and Infrastructure Security Agency’s (CISA) Chemical Facility Anti-Terrorism Standards (CFATS) program identifies and regulates high-risk chemical facilities to ensure appropriate security measures are in place. Under CFATS, a chemical facility is “any establishment that possesses or plans to possess...

Fertilizer Canada created the Anhydrous Ammonia Code of Practice (Ammonia Code) to provide uniform safety and security practices for the handling and storage of anhydrous ammonia at ag-retail facilities in Canada. The Ammonia Code outlines best practices applicable to the transportation, distribution, storage, and handling of anhydrous ammonia associated with these facilities. The Ammonia Code was...

NOTE: I normally do not post such small cases; however, this one involved the use of The Chlorine Institute pamphlets as the referenced RAGAGEP and because it is so rare we see Cl2 PSM/RMP citations I wanted to add it to the database. Based on a compliance monitoring inspection conducted at the Respondent’s facility on May 11, 2021, EPA alleges that the Respondent violated the Act’s Section...

Respondent is the owner and/or operator of the Facility, which operates an aircraft parts and auxiliary equipment manufacturing plant.  Respondent has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. At its Facility: … HomeRead More »

Respondent is the owner and/or operator of the facility, which produces fully cooked and ready-to-eat sauces and refrigerated entrees. On December 26, 2018, the EPA issued to Respondent a Notice of Potential Violation (“NOPV”), providing notice that the EPA found that Respondent potentially committed the alleged violations described in Section V of this Agreement and providing Respondent an opportunity...

This is another case where OSHA and EPA compliance may be the least of our concerns, as this is REAL LIFE process safety – NOT compliance work!  Yes, we have to comply with our repair RAGAGEP; but I was referring to whether a facility does a MOC or not.  Let’s examine this type of work and you may be surprised at my answer to “Is a MOC required when making repairs to an...

Although I agree with most of EPA’s FAQs regarding their RMP standard, this one is just sad!  The question was asked… Are Mechanical Controls Considered Administrative Controls? EPA and I could not be further apart on this topic, as EPA actually stated they would NOT accept an engineered hi-level alarm/interlock and would only accept a written procedure to control inventory involved...

EPA will, according to the regulations at 40 CFR §68.220(b), select stationary sources for audits based on any of the following criteria: … HomeRead More »

The prevention program requirements under 40 CFR Part 68, Subparts C and D, include “hazard reviews” and “process hazard analyses”. Is a “hazard review” synonymous with a “process hazard analysis” (PHA)? No, and here is the difference… … HomeRead More »

If an incident caused by theft or other criminal activity at a covered facility resulted in or could reasonably have resulted in a catastrophic release of a regulated substance, then the owner or operator of the covered facility must perform an incident investigation. If it would be unreasonable, based on the owner/operator’s knowledge of the facility and the safeguards that are in place, to...