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I am proud to announce that SAFTENG and The Chlorine Institute have renewed our partnership for another year (through 2026).  Members of The Chlorine Institute receive a FREE SAFTENG membership.  If you qualify, please contact me

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Not all biases are bad in safety; in fact one can be downright helpful
We hear a lot about our biases showing up in many SMS elements and how these biases hamper the SMS and mislead us.  But not all biases can be a bad thing.  One element where our biases shine brightly is in the Causal Analysis of accidents.  For decades now, we have been told over and over that 85% of accidents are due to human behaviors.  Most enter into the causal analysis exercise...
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Is a public road considered a public receptor?
A process covered under 40 CFR Part 68 is eligible for Program 1 requirements if it meets all of the criteria listed at 40 CFR §68.10(b). One of those criteria is that the distance to a toxic or flammable endpoint for a worst-case release assessment is less than the distance to any public receptor. Are roads covered as “public receptors?” … HomeRead More »
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Is a double walled tank "passive mitigation"?
Performance of the hazard assessment required under 40 CFR Part 68, Subpart B, includes analysis of both worst-case release scenarios (40 CFR §68.25) and alternative release scenarios (40 CFR §68.28). In each of these analyses, passive mitigation systems may be taken into consideration. If a tank has a “double wall,” does that qualify as “passive mitigation?” … HomeRead...
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Maintenance requirements for leased tanks
 I use propane as a raw material in my manufacturing process. I lease the tank from the propane supplier. The supplier does all the maintenance. My staff never work on the equipment. What should I do? … HomeRead More »
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States with authority to implement / enforce the risk management program rule
Which states have been granted a delegation of EPA’s authority to implement and enforce the risk management program rule? … HomeRead More »
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What is the definition of a "technically qualified individual"?
Certain exemptions may apply to determine whether more than a threshold amount of a regulated substance is present at a stationary source under 40 CFR Part 68. One exemption is for regulated substances that are “manufactured, processed, or used in a laboratory at a stationary source under the supervision of a technically qualified individual as defined in §720.3(ee) of this chapter” (40...
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After a reportable accident, do I have to revise my RMP?
I recently submitted my five-year RMP update required by section 68.190 (b)(1) and included my accident history for the previous five years. Two months later, we had another reportable accident. Do I have to do anything to revise my RMP? … HomeRead More »
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Who is responsible for preparing and submitting an RMP for leased propane tanks?
If an owner of a stationary source leases propane tanks from a gas supplier, who is responsible for preparing and submitting the risk management plan (RMP) addressing the propane tanks? … HomeRead More »
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How does this active mitigation system affect my selection and analysis of an alternative release scenario?
I run a wastewater treatment plant that is subject to the risk management program regulations in 40 CFR Part 68 for a covered process containing chlorine. A chlorine scrubber system at the plant is designed to prevent any possible releases from reaching a toxic endpoint offsite. How does this active mitigation system affect my selection and analysis of an alternative release scenario? …...
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Determining frequency of ER coordination activities
The Risk Management Program regulations require owners and operators of stationary sources to coordinate their response needs annually, or more frequently if necessary, with local emergency planning and response organizations (40 CFR §68.93(a)). Are stationary sources responsible for determining if coordination activities should occur more often than annually? … HomeRead More »
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RMP Records Maintained Onsite
Does the owner or operator have to maintain a written copy of the RMP on site at the stationary source? … HomeRead More »
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Are Mechanical Controls Considered Administrative Controls?
To analyze the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity (40 CFR §68.25(b)). Are mechanical controls such as alarms considered administrative controls and therefore...
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