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Have you granted your local Fire Department access to your Ammonia Machinery Room on a 24/7/365 basis?
This little matter always leads to an energetic discussion during our Emergency Response assessments/planning exercises.  But most states have a state code that will read something like this… Access to refrigeration systems having a refrigerant circuit containing more than 220 pounds (100 kg) of Group A1 or 30 pounds (14 kg) of any other group refrigerant shall be provided for the fire department...
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Never has an OSHA "Note" ever been so overlooked (1910.146)
There is a “Note” in OSHA’s Permit-Required Confined Space (PRCS) Standard(s) that seems to be overlooked by many who read the standard.  This “Note” is maybe the most important “Note” I have come across over my nearly 30 years in safety, so I am at a loss as to why so many misunderstand or overlook the “Note”.  The “Note”...
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OSHA clarifies the Walking-Working Surfaces final rule load capacity ratings in buildings?
Does the final rule require that employers post load capacity ratings in buildings? … HomeRead More »
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OSHA issues update to the Walking-Working Surfaces and Personal Fall Protection Systems Final Rule Frequently Asked Questions
A number of revisions were made to the existing general industry standards. Changes and new requirements include: (emphasis by me) … HomeRead More »
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Authentic leadership and work engagement: The indirect effects of psychological safety and trust in supervisors (Study)
This is a MUST READ for safety leaders.  It is scientific proof that CULTURE MATTERS to safety, and how we establish a culture of safety is with AUTHENTIC LEADERSHIP (w/ empathy) and how this BUILDS TRUST in the organization – most importantly, how this builds trust with the workers who do the dirty and dangerous work and their immediate supervisor. Research purpose:  This study aimed...
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Butane LB EO
Line Break gone bad (Butane w/ improper energy isolation)
An operator was working to remove a pressure gauge on what was assumed to be depressurized tubing. The upstream piping the pressure gauge tubing was connected to had been isolated, de-pressured and air-gapped so that this section of line was positively and physically isolated from the process. However, during the work to isolate the process line the section of tubing leading to the pressure gauge had...
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EPA RMP citations @ chemical manufacturing facility (NH3 & $98K)
Respondent is the owner and/or operator of a facility that uses anhydrous ammonia in its chemical manufacturing process.  EPA conducted an inspection of the Facility on April 13, 2016, to assess compliance with Section 112(r)(7) of the CAA (the “Inspection”) and the regulations at 40 C.F.R. Part 68. Respondent filed an RMP for the Facility with EPA on June 20, 2013, that, among other...
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Figure 1 schematic diagram
Small cracks grow up to become big cracks and big problems (NH3 direct expansion chiller)
A new direct expansion chiller was installed at an ice arena to replace an existing chiller. After almost 20 weeks of service, an ammonia leak was detected, which released ammonia into the machinery room. The low level (25 ppm) ammonia alarm sounded and the ventilation system was activated to continuously evacuate vapors to the outdoors while the location and nature of the leak were investigated. ...
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Why smoking while filling up is NOT a wise choice!
I do not know much about this video, such as where it was shot, was it a set up for demo or real-life.  But the FLIR footage is quite telling as we can see the vapors exiting the fill port.  These days in the USA a lot of stations have a “vapor-recovery” system so I am going to assume this station did NOT have such a system, but I do not know that for sure. … HomeRead...
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Carbon Dioxide (CO2) Delivery FATALITY (Drive-Off)
Bulk CO2 systems are becoming more and more commonplace.  Rather than having the smaller compressed gas cylinders from years back, restaurants are now running their soft drink dispensers off of liquid dewars which is a LOT of CO2.  Add to the mix that restaurants are notorious for having poor hazardous communications programs and YOUNGER workers – this move to increased inventory of...
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EPA publishes the FINAL RMP Rule (Rescinded Amendments)
The Environmental Protection Agency (EPA) has revised regulations designed to reduce the risk of accidental releases of hazardous chemicals. These regulations are part of the EPA’s Risk Management Program (RMP), which the Agency established under authority in the Clean Air Act and recently amended on January 13, 2017. After a process of reconsidering several parts of the 2017 rule, EPA has concluded...
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Safety is like the Wizard of Oz
Most practicing safety professionals in the USA have seen The Wizard of Oz.  This is an excellent movie, and it reminds me of our journey to achieve a safe workplace.  First … the Ruby Red slippers – many managers today state that “safety is #1”, that “our people are our #1 asset”, or “we do not want to see anyone get hurt.”  We should...
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