Anhydrous Ammonia is NOT a toxic nor highly toxic gas, as defined by the International Fire Code (IFC).  But if it is not managed as a “toxic,” how do we manage our ammonia gas? The IFC actually puts Anhydrous Ammonia in the… … HomeRead More »

I have been catching up on my Chlorine posts these last several weeks and some have asked me how I know which chemical goes into which hazard class; specifically, why Chlorine is “only toxic” and not “highly toxic”.  As I said in a few of my previous articles on safely managing Cl2, some of my businesses that had actual “highly toxic” materials went ahead and...

Chlorine is a “toxic gas” and as such it has special requirements in the IFC as well as the IMC. I have written about how we design our gas cabinets, gas rooms, enclosures, and storage areas based on the IFC Chapter 50 and 60 requirements. In this article, I will address the IMC requirements which are referenced in the IFC. I will be using the 2015 IMC for my references… …...

I have several chlorine projects going on and a couple of them are being installed by the same contractor, one of the best contractors in the chemical industry (I wish I could name them by my CA prevents me from listing them as a client or supporter!).  They used the pandemic to get everything installed and now we are ready for our post-construction and Pre-PSSR activities, which is when we do...

Respondent is the owner and/or operator of a candy manufacturing facility, which 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: a. Respondent produces food products b. Respondent has on-site for storage, 18,000 pounds of anhydrous ammonia c. Respondent has one RMProgram level 3 covered process,...

This redneck from western KY can understand one of the most fundamental requirements from ASME B31 standards… ONLY certified welders can make the welds AND each weld MUST be IDENTIFIED as to who made the weld(s)! Now ASME gives us options for meeting the “identification” requirements (e.g., stamping or Isometric Drawings). Still, these two requirements are a MUST-have for our PSM/RMP...

During my “lost years” early in my college days (i.e. before I discovered firefighting and OSH) I built swimming pools during the summers.  That job required a lot of piping work, which I got pretty good at, at least I thought I had until I got into my first Chlorine (Cl2) process as a safety engineer.  Now words mean a lot and when dealing with Cl2, DETAILS MATTER, so when I...

So far, I have discussed Evaporative Condensers and Spiral Freezers, making the case that most of these spaces are indeed Permit-Required Confined Spaces (PRCS).  This last space is gaining a lot of traction over the past 10-20 years, and still today, the design of most of these penthouses makes them, without a doubt, a PRCS.  In this last article in this series, I will break down the characteristics...

A worker at a water technology company suffered an injury when a guardrail loosened and he fell and struck his head on a support beam as he lowered himself into a nearly 30-foot deep water test pit. OSHA received the report of the injury on Oct. 29, 2020. Its inspectors later determined that the company exposed employees to walking-working surfaces hazards, failed to provide employees with fall protection...

This was buried in my archives by mistake until a member found it while digging through all the PowerPoint presentations.  It is from way back in 2008 when I was heavily involved in Water Treatment Plants and their use of Chlorine and the Chemical Facility Anti-Terrorism Standard (CFATS) roll-out.  The presentation was put together for a WWTP Summitt by MI-OSHA and is quite detailed as to...

Monika Chrzaszcz, U.S. EPA, Region 5, presented at this years MI Safety Conference on the matters of Anhydrous Ammonia and how the chemical impacts EPCRA and RMP.  Her presentation points out some of the RMP amendments that are in place now and those coming, as well as EPCRA Tier II reporting and release reporting.

NFPA 499, Recommended Practice for the Classification of Combustible Dusts and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas was updated for 2021 and this update involves a very peculiar reference that has me scratching my head.  This reference is also another example of why Safety and Process Safety professionals have come to hate RAGAGEPs and Consensus...