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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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EPA RMP Citations @ NH3, Urea, NH4NO3 manufacturing facility (CH4, H2, NH3, Cl2 & $30K)
Respondent is the owner and operator of the facility that produces anhydrous ammonia, urea fertilizer, and urea-ammonium nitrate which are loaded on trucks and railcars for distribution. The Respondent’s Facility chemical processes meet the definition of “process” and “covered process”, as defined by 40 C.F.R. § 68.3. The Respondent’s RMP program level 3 covered...
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1 entrant and 1 would-be-rescuer die in newly installed sewer (O2 Deficiency)
OSHA determined that an Arkansas construction contractor failed to test oxygen levels in the confined space before two workers entered a sewer 20 feet below ground at an Edmund work site and died because of a lack of oxygen.  The investigation into the June 14, 2022, incident found that an employee climbed into a newly installed sewer manhole to conduct testing when they lost consciousness. Trying...
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Don't let the tinsel on the tree blind you with the all the shine!
Every year about this time, I take time to reflect on the year.  This year I had the privilege to spend 100% of my time with Union Pacific Railroad, but I stayed connected with many of you, and through our many late-night discussions, I am reminded that many businesses get blinded by all the tinsel on the Christmas tree.  We now have three major movements within our profession. I am a fan...
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Safety Thought of the Week... Prevent-Protect-Mitigate
An ounce of PREVENTION is worth a pound of cure.   PREVENT   PROTECT     MITIGATE
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A call for getting back to the basics
Over my 30+ year career in safety and health, I have seen and participated in many “flavor of the month” initiatives.  Almost all of these were out desperately trying to achieve an OSHA rate.  I know; there’s a lot to unpack with that statement.  Probably the most significant movement of my career was the Behavior Based Safety movement in the 1990s and 2000s. ...
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"Weep Holes" are a requirement with a 3-prong alternative as back-up design (ASME Section VIII, Div 1,UG-136)
I am always amazed to hear people complain about the degree of our auditing.  Most clients hire us for detailed auditing, but some see the PSM/RMP 3-year audits as a “check-the-box” exercise and do not appreciate our auditing skills and experience (LOL).  Comments/Questions like… “Would OSHA really cite for that?” are commonplace.  Let me be clear; our job...
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The technical and safety crticial aspects of flanges, gaskets, and torquing
This topic can be hotly contested by some; why is beyond me.  Some businesses get lazy in their approach to process safety and convince themselves that flanged piping is cheaper (and easier) than joining the pipes using welding methods.  As we have discussed, welding our PRIMARY CONTAINMENT system, such as the piping, comes with many requirements to ensure we have the proper management system...
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Process Safety and LOCTITE®
I can not think of a single business that operated and maintained a PSM/RMP-covered process that did not utilize LOCTITE®.  It is a beautiful product; however, it may be the most overused and abused product within the covered process.  When used PROPERLY and per Henkel’s instructions, the product works well.  But like most really good products, it eventually leads to misuse in...
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Clarifying the differences between the OSHA and NFPA requirements for the Storage or Use of Flammable Liquids Inside of "Industrial Plants" or Similar Operations (MN-OSHA)
This Instruction STD from MI-OSHA is too good not to share with those who deal with 1910.106(e) and their flammable liquids safety efforts.  It does a nice job comparing the 1910.106 (which is based on the 1968 edition of NFPA 30) with the current NFPA 30 standard. … HomeRead More »
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Can I re-use my piping on another project?
You know businesses are cutting costs when I get this question.  But it is a good question as we have come across “reclaimed piping” being used in a lesser-degree hazard (e.g., flammable gas to flammable liquid) process.  I personally never experienced this practice in my time in industry, but it has become more popular as businesses look for more ways to reduce costs.  So...
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IFC and Bulk Loading/Unloading Flammable Liquids
If you have followed me for years, you know I love to use the International Fire Code over outdated OSHA standards.  For me, it is ALL about safety and not compliance; luckily, I have many clients who take the same approach, and we have made some serious improvements to a hazardous process.  Here is a lock at what the IFC states about Bulk Transfer and Process Transfer Operations (5706.5). I...
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Conducting a Periodic Inspection for Each Procedure in a Hazardous Energy Control (Lockout/Tagout) Program (NIOSH)
Employers are required by 29 CFR* § 1910.147(c)(6) to conduct a periodic inspection of written hazardous energy control (lockout/tagout) procedures.  The inspection must be performed at least once annually [per 12-month interval, as stated in 1910.147(c)(6)(i)] because of the significant risks associated with inadequate energy control procedures or the failure to properly implement them [OSHA...
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