It’s never a good sign when the EPA inspector is in the process and the operator’s personnel detector goes into alarm and the worried inspector is told… it was typical for the alarm to sound during sampling.  This led the inspector to inquire about this level of exposure for a repeated task such as sampling and that opened the door to three (3) SOP findings! Respondent operates...

We have discussed this numerous times over the years, but we rarely have a first-hand account of a “bleed” within a DB&B causing an LOPC event.  But because CALARP now has a Program 4 Incident Reporting trigger, we get to see firsthand how a 3/4″ bleeder on a 14″ pipe handling a HHC/EHS can cause a serious incident.   On October 5, 2018, a contract employee...

Way back in 2017, the state of California (CA) revised it’s Accidental Release Prevention program by adding a Program Level 4 for the state’s refineries.  In addition to the expanded prevention program requirements, the refineries are required to submit investigation reports, including root cause analysis after any major incident. But the one aspect of the Program 4 changes I...

OSHA currently regulates aspects of emergency response and preparedness; some of these standards were promulgated decades ago, and none were designed as comprehensive emergency response standards.  Consequently, they do not address the full range of hazards or concerns currently facing emergency responders, and other workers providing skilled support, nor do they reflect major changes in performance...

One of the top 5 nastiest checmicals I have encountered during my career is Hydrofluoric Acid and Hydrogen Fluoride (HF).  And it just amazes me that humans can convenience themselves that these chemicals are not “really that hazardous”.  TRUST ME (and NIOSH), HF has earned its place in my Top 5.  Of course, HF is not nearly as prevalent at Anyhrous Ammonia or Chlorine...

You walk by a power transmission shaft and notice that it is protruding out and seems to be missing its guard/cap.  You look all around for it, as we usually can find them sitting on the floor nearby!!!, but no luck.  So you report the “hazard” and issue a work-order to install a guard/cap over this protruding powered shaft.  Then someone asks… aren’t some of...

I have to first point out that OR-OSHA is a “state plan” ( and my personal favorite!) and is specific to employers in the state of Oregon (OR), but their 2020 LOI on maintaining SDSs electronically points out something that many (including me) have not considered.  I have been telling all my clients for decades that we have to maintain a “hard copy SDS manual” for those...

You may have seen this latest and greatest “detection method” in your junk mail, pop-up ads, or in a search of the internet.  These tapes work and they work well in my experiences, but as with any product, there are some serious drawbacks that one must understand before using these products.  Before I get into specifics, know that the addition of these tapes to your process safety...

Authorities: Napa man injured by flash fire while cleaning paper shredderA man was hospitalized Saturday morning with a burn injury suffered while cleaning a paper shredder, according to Napa Fire.  Firefighters were called to a west Napa house at about 7:50 a.m., where a man was being cooled in a shower after suffering a burn… The man had been using a can of compressed air to clean a shredder...

Many of you that handle anhydrous ammonia are familiar with The Compressed Gas Association’s (CGA) 2.1, Requirements for the Storage and Handling of Anhydrous Ammonia, which is the baseline RAGAGEP for ammonia fertilizer distributor facilities.  But the organization has another ammonia standard, G-2, Ammonia that is an EXCELLENT compliment to CGA 2.1.  The G-2 standard is a much broader...

We have discussed the Maximum Allowable Quantity (MAQ) extensively over the years, but a lot of facilities just can’t stay within the confines of a MAQ so what are they to do?  Well, it an easy answer but it is not so easy to meet!  In this article, I will explain the four (4) H occupancies and what it means to have an H occupancy – focusing on H-2 and H-3, as these are the most...

ME-OSHA issued two (2) Willfuls and six (6) serious citations to the Fire Department regarding the Sept. 16, 2019 explosion that killed a Captain in a propane explosion. The citations include up to $22,000 in potential fines for the town relating to violations of equipment and training standards. Here is a breakdown of the citations: … HomeRead More »