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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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Performance Influencing Factors PIFs
PIFs and Error Traps
Performance Influencing Factors (PIFs) is another term, from across the pond, for error traps.  You will see me use these terms interchangeably in my HF postings, as I was formally trained to use the term PIFs, but these days it seems we use the term trap.  But after spending a year working with an organization that performed many MANUAL HIGH-RISK tasks daily, I found the UK’s HSE infographic...
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Was it "technical failure" or "human error"?
In light of the tragedy in Greece this week, I think it is time to share this video from Lund University’s College of Human Factors Engineering again.  Be sure to check out all of Johan Bergström’s videos on YouTube.  A term in HFE seldom gets mentioned during accident investigations, as most will say it, “muddies the water” in the investigation. But the space between...
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API 574 now covers MI inspection/testing on hoses
Flexible hoses are often used to temporarily transfer hydrocarbons and other process fluids to facilitate turnaround activities (clearing equipment, de-inventorying, purging, etc.) and transfer process fluids/products to rail cars and/or/or tanker trucks for shipment. Flexible hoses may also be installed within process piping systems to mitigate the effects of thermal expansion, vibration, or movement...
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Flanged piping connections and a RAGAGEP's inspection basics
Facilities should have a written program to ensure flanges are properly made up. Proper makeup of every flange in a piping system is important for reliability. Proper makeup includes:  … HomeRead More »
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API 574 defines "Critical Check Valves" and 570 scopes their necessary inspection
The ever-controversial “check valve” has now been defined as to when it should be formally included in the piping MI inspection process.  As we have discussed many times, if we claim a check valve in our PHA and/or SOP as a “safeguard,” then by all means, this valve has been defacto identified as a “safety critical valve”.  Here is the official definition...
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For toxic endpoints, are milligrams per liter (mg / L) equivalent to parts per million (ppm)? (EPA RMP FAQ)
The endpoint concentrations for regulated toxic substances under the risk management program rule (40 CFR Part 68 Appendix A) are listed in units of milligrams per liter (mg/L). Is this equivalent to parts per million (ppm)? … HomeRead More »
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What measures qualify as "passive mitigation"? (EPA RMP FAQ)
Passive mitigation is defined in § 68.3 as “equipment, devices, or technologies that function without human, mechanical, or other energy input.” … HomeRead More »
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Determining thresholds for different chemicals in interconnected vessels (EPA RMP FAQ)
According to the definition of “process” in 40 CFR §68.3, any group of vessels that are interconnected is considered to be a single process. If a stationary source has two interconnected vessels and one contains 6,000 pounds of BUTANE while the other contains 6,000 pounds of PROPANE, is this a covered process under 40 CFR Part 68? … HomeRead More »
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How does EPA verify accuracy and completeness of RMPs? (EPA RMP FAQ)
What does EPA plan to do to verify the accuracy and completeness of submitted Risk Management Plans (RMPs)? … HomeRead More »
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Do the risk management program regulations cover the loading and unloading of transportation containers? (EPA RMP FAQ)
Would the risk management program regulations cover the loading and unloading of transportation containers? … HomeRead More »
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Are methane processes at landfills subject to RMP requirements? (EPA RMP FAQ)
Some landfills collect methane gas and either vent, flare, or store it for subsequent fuel use. Are methane processes at landfills subject to the requirements of the EPA Risk Management Program? … HomeRead More »
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Threshold determination for a single process with oleum and sulfur trioxide (EPA RMP FAQ)
Oleum, which is a mixture of sulfuric acid and sulfur trioxide, is listed as a regulated toxic substance in 40 CFR §68.130. Sulfur trioxide is also listed individually as a regulated toxic substance. Suppose a single process consists of one vessel containing oleum and one vessel containing sulfur trioxide. Must the amount of sulfur trioxide in the oleum be aggregated with the amount of pure sulfur...
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