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NEVER use the HHC/EHS as your pressure/leak testing media
On June 29, 2005, an operator was involved in the following maintenance activities in the Chloropyridines Complex at the employer’s chemical manufacturing facility. He was returning a reactor vessel to service and WAS ATTEMPTING TO DO A PRESSURE AND LEAK TEST USING CHLORINE GAS. The pipeline was supposed to be pressure tested with nitrogen gas during the previous shift. During the test, the employee...
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This is why ASME B31 series requires us to have written procedures for pressure and leak testing the piping
On March 13, 2007, Employee #1, a subcontractor, performed maintenance on commercial foodservice equipment. He was in the kitchen area of a single-story restaurant, attempting to locate the source of a refrigerant leak in an ice cream storage dipping cabinet. Employee #1 connected a Nitrogen cylinder to the dipping cabinet’s refrigeration system via a hose WITHOUT using a pressure reducing device,...
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Leak testing gone bad (Bubble test on NH3 pipe/valve weld)
A refrigeration system was being installed in a new wing of an ice cream plant in 1984.  A leak test was being performed by employee #1 on a “low-pressure tank” which was filled with a mixture of ammonia and air under a pressure of 150 psi. As he squirted a soap bubble solution onto a butterfly valve, the valve suddenly popped completely open. The force of the outrushing NH3/Air gases...
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Line Break gone BAD (replacing a defective NH3 pressure gauge)
At 11:30 a.m. on September 04, 2018, a group of employees was working on a beef processing station. Employee #1 was REPLACING A DEFECTIVE AMMONIA PRESSURE GAUGE FOR A HOT-GAS AMMONIA LINE when he broke off the gauge and associated valve, releasing ammonia into the area and cut/fab floor below. The plant was evacuated and 14 employees were treated and released for ammonia exposure and one employee was...
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Hand sanitizers that have 60% Alcohol are Category 3 FLAMMABLE LIQUIDS (Part II)
My March 16th article about the hand sanitizers being a CAT 3 Flammable Liquid caused quite the ruckus.  Many did not want to accept the fact until they went and found out on their own that these alcohol-based hand sanitizers are indeed flammable liquids.  And once they came to this realization the questions started to pour in.  The International Fire Code (I am using the 2018 edition)...
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The mortality rate is really low for COVID-19 so this is overkill (all pun intended)...
This is the new mantra being spewed by the none believers now that the infection rate has destroyed their earlier argument that the virus is not a problem in the USA.  Here is the full story as to why our mortality rate is trending so low right now… EARLY in the spread, relatively few need medical care at this time.  What happens with these pandemics is the medical care is overrun because...
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EPA RMP citations @ LPG Railcar filling facility (LPG & $14K)
On July 12, 2017, authorized EPA representatives conducted a compliance inspection of the facility to determine its compliance with the Risk Management Program (“RMP”) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Act. Following the inspection, EPA requested certain documents and information and reviewed the provided information with support from outside specialists....
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2019 Summary of U.S. Agricultural Confined Space-Related Injuries and Fatalities (Purdue University)
Since the 1970’s Purdue University’s Agricultural and Biological Engineering Department has been documenting and investigating incidents involving grain storage and handling facilities at both commercial and on-farm locations. Beginning in 2013, the effort was expanded, with support from a U.S. Department of LaborSusan Harwood Training Grant, to include incidents involving grain transport vehicles...
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Working from Home and OSHA
NOTE:  Under our Pandemic, my bet OSHA is not going to enforce a lot of this, but I thought it would be a timely reminder as I have received numerous questions about working from home. The OSH Act applies to work performed by an employee in any workplace within the United States, including a workplace located in the employee’s home. All employers, including those which have entered into...
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EPA RMP GDC citations @ refrigerated warehouse and storage facilities (NH3 & $179K)
Section 112 (r)(1) of the Act, commonly referred to as the General Duty Clause addresses the prevention of releases of substances listed pursuant to Section 112(r)(3) ofthe Act, or any other extremely hazardous substance. The purpose of this section is to prevent the accidental release of extremely hazardous substances and to minimize the consequences of such releases. The General Duty Clause provides...
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EPA required to issue rules requiring hazardous substance spill-prevention and response planning in the next 2 years
The U.S. District Court for the Southern District of New York has approved a consent decree between the U.S. Environmental Protection Agency and the Environmental Justice Health Alliance for Chemical Policy Reform, Clean Water Action, and Natural Resources Defense Council. The consent decree requires EPA to issue long-overdue rules requiring robust hazardous substance spill-prevention and response...
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Hand sanitizers that have 60% Alcohol are Category 3 FLAMMABLE LIQUIDS
When your hand sanitizer has 50% more Alcohol it will be at least a Category 3 Flammable Liquid – just review the SDS for your product of choice if you doubt me.  In fact, some hand sanitizers with higher Alcohol percentages may be a Category 2 Flammable Liquid.  In the light of COVID-19 virus pandemic, these products are being hoarded in large quantities by individuals and I can assure...
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