Canada has an interesting requirement for their NH3 refrigeration plants that operate within structures where the general public could be exposed to the NH3.  Since the promulgation of OSHA’s PSM standards in 1992, OSHA has shied away from even mentioning “staffing” for a covered process.  In the USA, we have plants that run 24/7/365 without trained refrigeration personnel...

We have yet another failure of enormous proportions.  When two workers, one of which is a Supervisor, are opening a liquid chlorine line and they have on supplied-air respirators without the regulator attached to the facepiece we have entered into the Twilight Zone.   WorksafeBC has levied a $318,707 fine against the city’s water-treatment plant for: … HomeRead More...

Whether we’re in process safety or just good ole fashioned occupational safety and health, the act of performing hot work (welding to the layperson – my feeble attempt at some Dumb and Dumber humor) can be one of the most dangerous task workers can perform.  Add in the fact the hot work is done within a PSM/RMP “covered process” and the risk rise substantially.  But...

We have a machine and this machine has a couple of tasks that have been deemed “minor servicing”.  As we walk by we see a worker in the machine and no LOTO in place so of course we stop and ask about the situation.  We are told the task being done, “XXXXXXXX”, is indeed a “minor servicing” task approved by the safety department.  We continue on our...

Bollards – a safety engineer’s best friend and a facility engineer’s worst nightmare.  I am not quite sure how we lost our way in such a simple design for such a significant safeguard.  But the International Fire Code (IFC) since the early 1990’s when I began using it has remained consistent in the design of Bollards.  I am not even aware of any other design standard...

Last year I was attending some continuing education for my hazardous materials work.  The instructor was outstanding until he went on his tirade against Nitrogen (N2).  He was factually correct when he stated that N2 was a leading killer within confined spaces, but he went off the rails when he tried to convince me that N2 is a toxic hazard and it is this toxic hazard that is killing workers. ...

Respondent is a business that owns and operates two (2) refrigerated warehouse and storage facilities located in Nebraska and Minnesota. The Nebraska facility is located in EPA Region 7 and the Minnesota facility is located in EPA Region 5. Information gathered during the EPA inspection revealed that Respondent had greater than 10,000 pounds of anhydrous ammonia in a process at its Nebraska facility....

Here is an initial look at the rule, signed by the CSB Interim Executive today. The final rule requires an owner or operator of a stationary source to submit an accidental release report to the CSB. The rule describes when to file a report of an accidental release and the required content of such a report. The purpose of the rule is to ensure that the CSB receives rapid, accurate reports of any accidental...

Attached is the written program for General Industry facilities which incorporate OSHA’s newer Confined Spaces in Construction requirements.  It is my recommendation that we UPDATE our written program that was based on the older 1910.146 standard to include all the improvements in 1926.1201 – .1213.  We should also understand that even though our facility may fall within OSHA...

The Risk Management Program (RMP) regulations require the owner or operator of a stationary source to revise and update the source’s RMP at least once every five years from the date of its initial submission or most recent full update (§68.190(b)).  Is there a procedure for obtaining an extension to complete the five-year review?  … HomeRead More »

The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency planning and response organizations...

How much time does the owner or operator of a stationary source have to submit a correction to a Risk Management Plan when the emergency contact information changes? The Risk Management Plan (RMP) regulations require an owner or operator of a stationary source to correct their RMP within one month (i.e., 30 days) of any change in the emergency contact information required under 40 CFR 68.160(b)(6)...