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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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Metal Storage Cabinet
Design, Construction, and Capacity of Flammable Liquid Storage Cabinets
Another great review on the design, construction, and capacity of flammable storage cabinets, a topic that seems never to go away. Safety Tip: Single-walled supply cabinets do not work. … HomeRead More »
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RMP Facilties
EPA Should Ensure Regulated Facilities Consider Risks from Climate Change
Why GAO Did This Study? Over 11,000 RMP facilities across the nation have extremely hazardous chemicals in amounts that could harm people, property, or the environment if accidentally released. Risks to these facilities include those posed by natural hazards, which may damage the facilities and potentially release the chemicals into surrounding communities. Climate change mayAccording to the Fourth...
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Determining the amount released for Ammonia and Ammonium Hydroxide for Release Notification Requirements under CERCLA section 103 and EPCRA section 304
Ammonia (CAS# 7664-41-7) is an Extremely Hazardous Substance (EHS), listed at 40 CFR Part 355 Appendix A  EPA website and Appendix B with a reportable quantity (RQ) of 100 lbs. Both ammonia and ammonium hydroxide (CAS# 1336-21-6) are listed as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substances at 40 CFR 302.4. Under CERCLA, ammonia is listed with...
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Emergency Response Coordination Activities Effective Date
The RMP Amendments, finalized on January 13, 2017, included a requirement for owners or operators of a stationary source to engage in emergency response coordination activities (40 CFR §68.93). The regulatory text in 40 CFR §68.10(b) states that compliance with these activities must be completed by March 14, 2018. Because the RMP Amendments were not effective until September 21, 2018, are facilities...
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Personal Human Factors Failure experience
I want to share a perfect failure scenario that happened to me and has been happening to me since April 2021. And yes, I see the world through the lens of a safety engineer – hate me for it if you must.  The failure is 99% my fault for trusting a simple financial tool via my AMEX credit card.  This morning Becky alerted me to a repeated charge on my card for $8.61.  It was for...
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Process Safety's Hierarchy of Controls and Inherent Safety (Trevor Kletz)
Most formally educated or well-trained safety professionals are familiar with the Hierarchy of Controls.  We use this approach daily in our work to reduce the likelihood of an event and/or the event’s severity.  Mr. Kletz always had a different take on using this philosophy in process safety and as always – he nailed it! … HomeRead More »
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EPA issues RMP citations @ chemical manufacturing facility (NH3 & $36K)
Respondent has an Ethanolamines unit used for chemical manufacturing purposes at the Facility that has greater than a threshold quantity of anhydrous ammonia.  EPA Findings of Violation Count 1 – Quality Assurance … HomeRead More »
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Hazards of filling your own LPG cylinders
At 9:00 a.m. on January 31, 2022, an employee who worked as a General Laborer fo r an Industrial Nursery was filling propane cylinders from a bulk propane tank. As the employee was finishing filling a cylinder, he began to remove the filling hose before shutting off the propane. As a result, the gas escaped and caused freezing burns to the employee’s hands, requiring hospitalization. …...
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Understanding Dr. Reasons Vulnerable System Syndrome (VSS)
Investigations of accidents in a number of hazardous domains suggest that a cluster of organizational pathologies—the “vulnerable system syndrome” (VSS)—render some systems more liable to adverse events. This syndrome has three (3) interacting and self-perpetuating elements: Blaming front-line individuals, Denying the existence of systemic error provoking weaknesses and Blinkered pursuit...
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PRCS Non-Entry Rescue System
productThis week I have been helping a client/friend understand what a true non-entry rescue system looks like and how it functions.  Back in July 2011, I wrote an article titled “CS Rescue… Tripods and Winches and a false sense of security” to help facilities understand the vast limitations of the traditional tripod and winch setup.  Namely, that setup works ONLY when you...
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EPA issues RMP citations @ water treatment plant (Cl2 & $83K)
The respondent operates a water chlorination process. On July 27, 2021, EPA conducted an announced inspection of the Facility. The Facility maintains a maximum inventory of 14,000 pounds of chlorine, a regulated substance, as a liquified compressed gas in 1-ton cylinders. Here are the findings from the inspection: … HomeRead More »
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Workplace Trust and Safety Benefits
Workplace Trust and Safety Benefits
I found another ppt from years ago, dusted it off, and updated it for a client.  This is based on many of the HOP/HPI/Resiliency talks we hear these days.  But know this, without trust, NOTHING will work in our effort to improve the worker’s safety.  My favorite saying on trust is from Dr. Clive Lloyd: “Unless the mistrust of the workforce can be overcome, then even the most...
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