The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency planning and response organizations...

On August 18, 2018, the EPA issued to Respondent a Notice of Potential Violation (“NOPV”), providing notice that the EPA found that Respondent had potentially committed the alleged violations described in Section V of this Agreement and providing Respondent an opportunity to confer with the EPA. On February 14, 2019, representatives of Respondent and the EPA discussed the August 18, 2018, NOPV. ...

The Pipeline and Hazardous Materials Safety Administration (PHMSA) has developed a free, mobile web app of its Emergency Response Guidebook 2020 (ERG). The new safety tool provides the nation’s emergency responders with fast, easily accessible information to help them manage hazardous material incidents. This software is available from the Apple iTunes store for iPhone, and from the Google Play...

A wise plant manager told me this in my first year in the petrochem industry.  I am paraphrasing When it comes to our primary containment systems (he was speaking to piping in this discussion) – if it is not done darn near perfect, all we have to do is wait a while and bad things will just begin happen.  But when it is done darn near perfect (as required by ASME B31.3) AND we have the...

OSHA does not mandate that employers establish fire brigades; however, if they do so, they must comply with the provisions of the Fire Brigades Standard. The provisions of the standard, including the paperwork requirements, apply to fire brigades, industrial fire departments, and private or contract fire departments, but not to airport crash rescue units or forest firefighting operations.  Paragraphs...

As I stated last week and posted my updated RMP Audit Checklist ER questions, the RMP ER coordination activities should be at least in your “planning/discussion” phase with your off-site responders/resources.  Even though 68.10(b) states that compliance with these activities must be completed by March 14, 2018 and the fact that the amendments did not become effective until September...

Back in December 2017, I wrote an article explaining how this new nitrification inhibitor in the ammonia fertilizer industry would impact the facility’s PSM/RMP programs.  I received a lot of questions and nasty grams from that article, but one thing I forgot to mention is how this new “blending” operation changes the retail locations EPCRA Sections 311 and 312 reporting. ...

Today, the NFPA adopted some interesting revisions to their NFPA 350, Guide for Safe Confined Space Entry and Work.  One item that many may find interesting is 8.6.5 Pipes and lines that run through a confined space… Here are the most notable updates/revisions: Non-Members can find the changes Here. … HomeRead More »

For SAFTENG clients and members, I have updated my PSM/RMP audit checklist (the old OSHA PQV checklist) with EPA’s most recent amendment regarding the Emergency Response requirements for Responding and Non-Responding facilities.  Keep in mind that these new requirements are “officially” ONLY required when the facility is an RMP facility; if the process(s) is ONLY covered by OSHA’s...

One (1) bolt on a five(5) bolt flange was left loose by just one full turn and we have a small release of a flammable gas… EXCELLENT video by Baker Risk.

From 2011 to 2018, 1,030 workers died from occupational injuries involving a confined space. The annual figures range from a low of 88 in 2012 to a high of 166 in 2017. Fatal occupational injuries involving confined spaces, 2011-2018 Year 2011 2012 2013 2014 2015 2016 2017 2018 Fatal work injuries 120 88 112 116 136 144 166 148 As documents in a fatal injury work injury case may vary, cases...