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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's RMP "Responding Facility" flowchart
One of the most heated debates in the process safety arena is… Do I have to have an emergency response team?  EPA has worked to answer this question by designating facilities as “responding” and “Non-responding” facilities.  Here is a nice flow chart to help… … HomeRead More »
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EPA issues RMP citations @ manufacturing facility (Ethylene and Vinyl Acetate Monomer & $17K w/ $65K SEP)
Respondent is the owner and operator of the facility that produces, processes, stores, or handles more than 10,000 pounds of ethylene and more than 15,000 pounds of vinyl acetate monomer (Acetic acid ethenyl ester). The EPA inspected the Facility from January 16, 2020 to January 17, 2020, to determine the Respondent’s compliance with 40 C.F .R. Part 68. Ethylene and vinyl acetate monomer are...
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Buyer Beware - OSHA 10-Hour General Industry course does NOT make a facility compliant
In the past 4-5 months, I have received numerous phone calls and e-mails from friends/clients regarding their desire to hold an OSHA 10-hour course for their employees.  Most of this is driven by the idea that they believed, as they were told by some less than scrupulous consultants, that OSHA would accept their 10-hr card as meeting the required annual safety training for employees.  One...
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Compressor Oil Feed Pump
Ammonia leak from comperssor oil pump
This ammonia refrigeration process is equipped with an oil transfer pump that transfers fresh refrigeration oil from a barrel to fill up the compressor oil separators to the operating oil level. However, the oil pump has been idle for a prolonged period, with the electrical power connection incomplete.  Conversely, the associated piping system seems completed. One end of the oil distribution...
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New Safety Policy – Analysis of Secondary Coolant (TECHNICAL SAFETY AUTHORITY OF SASKATCHEWAN)
One way to reduce the risk of an ammonia leak is by monitoring for leakage through the analysis of the secondary coolant (often brine) for signs of ammonia. The secondary coolant in an indirect Ammonia system must be tested no less than twice a year. Information Paper IP-BPV-2021-08-01 outlines the requirements for a secondary coolant analysis that your TSASK inspector will enforce during...
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OSHA defines "Line Breaking"
One of the most dangerous tasks that occur within the battery limits of a covered process is “opening the process.”  This is commonly called a “Line Break” but also applies to vessels.  We won’t find a definition of “Line Breaking” in the PSM Standard; instead, we turn to OSHA’s Permit-Required Confined Space Standards (1910.146 and 1926.1201-.1213). ...
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Process Safety and OSHA Standards
One of the biggest hurdles for an organization entering OSHA’s and EPA’s process safety standards is that some old OSHA standards are just NOT adequate based on the new level of risks.  This is most noticeable are with flammable liquid processes.  Take, for example, 1910.106, OSHA’s Flammable liquids standard.  It is “OK” for businesses that use flammable...
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cracked PV air receiver
Proper installation of ASME Pressure Vessels is key
A licensed contractor installed two newly manufactured vertical machine-mounted air receivers for instrument air processes at a wood treatment facility in November 2020.  During a scheduled maintenance service after eight months of operation, cracks were located on the top head of each vessel, specifically at the head-to-bracket weld fillet welds. The cracking was in similar areas on both vessel...
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Oil Pot Relief Valve
600 pound NH3 release from refrigeration process (Ice Rink)
This ammonia refrigeration system for the ice rink had been shut down, and the full ammonia charge (800 pounds) was being stored in the chiller, attached surge vessel, and the oil pot.  Three (3) days before the incident, a contractor was doing maintenance on the brine system to install a pH sensor in the brine pump discharge piping upstream of the pump’s discharge isolator (Image 4).  When...
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CAL OSHA LOTO Guide
CALOSHA's revises its Controls for Hazardous Energies Guide
Last month CAL-OSHA issued a revised guide on Controls for Hazardous Energies.  This is a MUST-HAVE for all safety professionals responsible for their Lockout/Tagout (LOTO) Program.  Never mind that it is a State OSHA program publication – this is a solid document that explains the in’s and out’s of LOTO.  My favorite section… Interlocks Are Not a Substitute for...
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Covid-19: OSHA’s enforcement activities did not sufficiently protect workers from pandemic health hazards
WHY OIG CONDUCTED THE AUDIT The Occupational Safety and Health Administration (OSHA) is responsible for ensuring safe and healthful working conditions for 130 million workers employed at more than 8 million worksites. It does so by setting and enforcing standards and by providing training, outreach, education, and assistance to employers and employees. The COVID-19 pandemic has presented OSHA with...
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Regulatory Requirements that Satisfy CFATS Risk-Based Performance Standards (RBPS)
The Chemical Facility Anti-Terrorism Standards (CFATS) program requires high-risk facilities to ensure security measures are in place to reduce the risk of more than 300 chemicals of interest (COI) being weaponized. High-risk facilities are assigned to one of four (4) risk-based tiers and must develop a security plan meeting the 18 Risk-Based Performance Standards (RBPS).  Due to the nature of...
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