Under most circumstances, where servicing or maintenance is to be conducted during only one shift by a small number of persons, the installation of each individual’s LOTO device on each energy isolation device would not be a burdensome procedure. However, when complex equipment is being serviced or maintained, when there are many sources of energy, and/or when servicing/maintenance work extends...

The first element is whether strategic plans and action plans integrate safety into all aspects of an organization’s activities. Are there measurable short, medium, and long-term safety objectives in these plans, and is there regular progress monitoring in implementing the plans? Monitoring progress by the senior management team is vital to good safety leadership. Regular plans should be reviewed to...

Anyone who has played sports or even just attended a team sporting event has heard or seen the famous saying: There is no “I” in Team! In our world of Lockout/Tagout (LOTO), nothing could be farther from the truth!  There is not an act in occupational safety and health that is more self-serving and selfish than LOTO.  Even in Group LOTO situations, LOTO is ALL about EACH WORKER...

Can cylinders of Anhydrous Ammonia (NH3) be stored with oxygen cylinders?  This is not meant to be a trick question, but it is a question I find to be confusing for employees who place cylinders into storage.  So what is your answer: Can cylinders of Anhydrous Ammonia (NH3) be stored with oxygen cylinders? … HomeRead More »

Respondent operates a seafood processing facility where anhydrous ammonia was present in a process above the 10,000 pounds TQ. Respondent has one program 3 process, an ammonia refrigeration process consisting of a brine chiller system, seven plate freezers, one blast freezer and one ice house with three ice machines. An RMP was submitted for the Facility on February 14, 2014, and March 27, 2019. ...

The following is a list of key safety measures developed by EPA in coordination with the International Institute of Ammonia Refrigeration (IIAR). They are measures that EPA and IIAR agree are required elements for ammonia refrigeration facilities (regardless of an ammonia refrigeration system’s age or size) for the system to meet the requirements of 40 C.F.R. Part 68 or the General Duty Clause...

First I want to thank my Pittsburg friends for another great visit and for being my “think-tank” of world-class engineers and chemists.  I always leave smarter and happier after my time with these folks.  And with all my visits I always come away with great real-world examples of how process safety is supposed to be done!  For years I have been harping on using a “tell-tale...

As we discussed last week, the 7th Edition of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) has quite the change as it relates to flammable gases.  We now know there are three (3) Categories of flammable Gases:  1A, 1B, and 2.  The 1B is the new one and was in put in place to manage the new flammable refrigerants that are replacing the Ozone Depleting...

First thing – Rest In Peace Gerardo Castorena and Frank Flores and may God be with your loved ones during this most difficult time.  Also to the residents who have lost their homes and/or been displaced, I wish you a speedy return to some sense of normalcy.  And to the workers who have lost their way of living and wonder what their future holds I wish you peace of mind and comfort. I...

Each time I share a video of foolishness putting people at risk I always catch slack from people in the USA about how the video shows “3rd world behaviors” – never mind all the videos and pics showing Americans at gas pumps using plastic bags, 5-gallon buckets, etc. at fuel pumps.  Here is another one from within the USA; it is quite worrisome as the young lady is being directed...

During stakeholder outreach as part of EO 13650 and during OSHA’s PSM SBREFA (Small Business Regulatory Enforcement Fairness Act), OSHA and EPA received multiple comments from stakeholders expressing confusion on the applicability and overlap between OSHA’s Process Safety Management (PSM) standard and EPA’s Risk Management Plan (RMP) regulation. In the Clean Air Act Amendments of...

I have written over a dozen articles on the big change in automobile manufacturing and their new refrigerant HFO-1234yf which is going into almost all vehicles made today.  Today HFO-1234yf is a Category 1 Flammable gas, hence it is a Highly Hazardous Chemical (HHC) and when the process exceeds 10,000 pounds of this refrigerant the process is a PSM Covered Process.  That is today and in December...