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safe distance infographic
I have created a "cheat sheet" for safe distances during pneumatic pressure testing (ASME PCC-2, Mandatory Appendix 501-III)
DISCLAIMER: This is a “cheat sheet” for safety professionals to get a general idea of the “safe distances.” ALWAYS refer to ASME PCC-2, Mandatory Appendix 501-III) for the exact distance. Just understand, ALL pneumatic pressure testing REQUIRES a “safe distance”. According to ASME PCC-2, Mandatory Appendix 501-III, determining safe distances for pressure testing—specifically,...
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EPA RMP image
Why I rarely allow "Release in enclosed space, in direct contact with outside air" to be credited in my WCS's (NH3)
So I asked Google Gemni + to calculate the pressure wave in a room that is 40′ X 40′ X 20′ tall with a 5,000-gallon pressure vessel 85% full of liquid NH3, and it catastrophically fails. How much of a pressure wave will this event create in psig? I promise you this… No Engine Room I have ever been in could withstand this event! Google Gemini + equated it to TNT! …...
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EPA RMP image
When to Revise Off-Site Consequence Analysis (EPA FAQ)
The risk management program in 40 CFR Part 68 requires facilities to conduct an off-site consequence analysis (OCA) to provide information to state, local, and federal governments and the public about the potential consequences of an accidental chemical release. When does a facility need to revise its OCA? … HomeRead More »
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EPA RMP image
Are Mechanical Controls Considered Administrative Controls? (EMP RMP OCAs)
For the purpose of analyzing 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...
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EPA RMP image
Worst-case Release Scenario for Separate, Interconnected Vessels (EPA FAQ)
Pursuant to the risk management program regulations, facilities must perform an offsite consequence analysis for the worst-case release scenario. Do the quantities of two (2) separate vessels that are interconnected with a closed valve need to be aggregated for the worst-case release scenario analysis?  … HomeRead More »
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EPA RMP image
Worst-case “quantity released” reporting for a mixture (EPA FAQ)
In section 2, element 2.5, of an RMP, facilities must report the quantity of toxic chemical that the facility used for the worst-case analysis. When reporting this data element in RMP*eSubmit for a mixture, should facilities report the entire weight of the toxic mixture potentially being released or only the amount of the regulated toxic substance in the mixture? … HomeRead More »
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EPA RMP image
Ammonia (concentration 20% or greater) and Ammonia (anhydrous) Alternative Release Scenarios (EPA FAQ)
Pursuant to the Risk Management Program regulations, the owner or operator shall identify and analyze at least one (1) alternative release scenario for each regulated toxic substance held in a Program 2 or Program 3 process above its threshold (40 CFR §68.28). If a facility has both ammonia and ammonia (anhydrous) on site above their respective thresholds, does the facility owner or operator need...
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EPA RMP image
Are exercises required as a part of the emergency response program requirements under 40 CFR Part 68, Subpart E? (EPA FAQ)
Yes. … HomeRead More »
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NFPA's Tentative Interim Amendment (TIA) 27-1 - 2027 Edition of NFPA 30
Tentative Interim Amendment (TIA) 27-1 refers to a significant update to the 2027 Edition of NFPA 30: Flammable and Combustible Liquids Code. Issued on April 15, 2026, with an effective date of May 5, 2026, this TIA (Log #1886) was processed by the Technical Committee on Flammable and Combustible Liquids to address safety gaps regarding the handling of ignitible liquids in specific occupancy types....
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CAL OSHA HCA
What is a Hierarchy of Hazard Control Analysis (HCA)?
Under Cal/OSHA’s Process Safety Management (PSM) standards (specifically Title 8 §5189.1 for refineries and §5110.16 for other facilities), the Hierarchy of Hazard Control Analysis (HCA) is a formal, documented requirement that goes significantly beyond the traditional OSHA “inverted pyramid.” While standard safety protocols often treat the hierarchy as a suggestion, Cal/OSHA makes it...
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The CSB’s Fiscal Year 2026 Top Management Challenges
A new report from the EPA Office of Inspector General (May 6) highlighted that the U.S. Chemical Safety Board (CSB) is currently operating at only 40% board capacity (two out of five members), which restricts its ability to formally approve investigation reports and safety recommendations. The Clean Air Act Amendments of 1990 established that the CSB’s board shall consist of five board members, including...
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OSHA Heat NEP
Understanding OSHA's Revised Heat National Emphasis Program (NEP)
The revised Heat National Emphasis Program (NEP), relaunched on April 10, 2026, represents a major shift in how OSHA handles heat-related enforcement. This isn’t just a renewal of the 2022 program; it is a full five-year directive (running through 2031) that gives inspectors more power to enter workplaces without a prior complaint. OSHA no longer waits for a heatwave to act. The program defines...
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