NOTE:  I have always said city/county governments get huge breaks in $’s when it comes to RMP citations.  A private company who performed this poorly in an inspection would have gotten 10X’s the citation $’s. On November 9, 2016, an authorized EPA representative conducted a compliance inspection of the Water Treatment Plant (“Facility”) to determine its compliance...

At its stationary source, the Respondent operates a Polystrene Foam Production facility using butane and has 132,235 pounds of butane in onsite storage. At its stationary source, the Respondent has one RMProgram level 3 covered process, which processes butane in an amount exceeding its applicable threshold of 10,000 pounds. On August 30, 2018, the EPA conducted an onsite inspection of the RMProgram...

OSHA has expanded temporary guidance provided in a March 14, 2020, memorandum regarding supply shortages of N95s or other filtering facepiece respirators (FFRs) due to the COVID-19 pandemic. This expanded guidance applies to all workplaces covered by OSHA where there is required respirator use. OSHA field offices will exercise enforcement discretion concerning annual fit-testing requirements, as long...

The Department of Health and Human Service (HHS) is publishing this interim final rule to update the regulatory requirements used by the Centers for Disease Control and Prevention’s (CDC) National Institute for Occupational Safety and Health (NIOSH)to test and approve air-purifying particulate respirators for use in the ongoing public health emergency. With this rulemaking, parallel performance standards...

I have written several articles lately explaining the limitations of storing flammables and toxics.  A couple of these articles referenced the International Fire Code (IFC) which is my favorite safety code for hazardous materials.  OSHA’s 1910.106 is from the 1969 NFPA 30 and has not been sustainably updated since; whereas the IFC gets updated every three (3) years.  In the IFC...

This memorandum expands temporary enforcement guidance provided in OSHA’s March 14, 2020, memorandum to Compliance Safety and Health Officers for enforcing annual fit-testing requirements of the Respiratory Protection standard, 29 CFR § 1910.134(f)(2), with regard to supply shortages of N95s or other filtering facepiece respirators (FFRs) due to the coronavirus disease 2019 (COVID-19) pandemic.[1] The...

These two terms are often discussed on OSHA outreach training courses, but I hardly ever mention them as they are more “legal” terms than safety terms.  But this month, MI-OSHA issued guidance to their CSHO’s which I thought did a really nice job explaining what these terms mean and how they are used in issuing citations.  Vertical Standards – Standards that apply to a particular...

WorkSafe Victoria is issuing a safety alert highlighting the hazards associated with using small-bore fittings following a number of recent incidents at Major Hazard Facilities (MHF).  WorkSafe has recently been notified of three separate incidents involving the loss of containment of highly toxic and corrosive chemicals caused by the use of small-bore fittings for temporary connections. The connections...

This is a tale of Valve Handle Positions and the assumption the valve was CLOSED based on the position the handle was found in.  No Lockout/Tagout and NO VERIFICATION of a Zero Energy State (ZES) before the NG pipe was disassembled. I am not sure why the NTSB makes no mention of “Energy Control” (e.g. Lockout/Tagout) in this accident report,  but it was clear a needed administrative...

We have discussed the hazards and risks associated with the transferring of hazardous materials in bulk.  This case was a terminal to ship transfer, but these basic failures can happen on any transfer.  Not following procedures, not utilizing an unloading checklist, and not using the unloading process and the nitrogen purge process as it was DESIGNED all led to this OVER PRESSURE EVENT involving...

Well, we knew it would just be a matter of time until someone did this.  Again, the fear of contracting a virus has apparently overridden all rational thinking.  This picture was shared this morning in one of my favorite Facebook Groups Fire Inspectors With No Borders.   We do not know the background of the picture, but in this pandemic, we (group members) assumed it was more make-shift...

        This past month we have lived with the COVID19 pandemic and the fear that comes with it.  I have spent hours trying to stop one of the social media myths about COVID19 and gas pump handles.  There have been viral posts suggesting that people use plastic shopping bags to handle the gas pump handle so they could avoid having to touch the handle directly for fear...