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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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Process identification and distance between vessels (EPA RMP)
How far apart do separate vessels have to be to be considered different processes? … HomeRead More »
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Do I have to report accidents that resulted in medical treatment? (EPA RMP)
I had a release where several people were treated at the hospital and released; they attributed their symptoms to exposure. We do not believe that their symptoms were in fact the result of exposure to the released substance. Do we have to report these as offsite impacts? … HomeRead More »
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EPA's Hot Work Definition and Requirements
Facilities subject to the Program 3 Prevention Program requirements in 40 CFR Part 68 must include in their Risk Management Plan the date of the most recent review or revision of hot work permit procedures in Section 7.13. What is considered hot work and what are the requirements related to hot work? … HomeRead More »
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Different distances to toxic endpoints with different versions of RMP*Comp
I’ve noticed that for certain chemicals, RMP*Comp gives substantially different distances to the toxic endpoint than previous versions. Why? … HomeRead More »
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Is a hazard review synonymous with a process hazard analysis (PHA)?
The prevention program requirements under 40 CFR Part 68, Subparts C and D, include hazard reviews and process hazard analyses. Is a hazard review synonymous with a process hazard analysis (PHA)? No! … HomeRead More »
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Why are industries exempt under OSHA's PSM subject to RMP?
The Program 3 prevention program requirements under 40 CFR Part 68 are almost identical to the requirements of OSHA’s process safety management (PSM) standard. OSHA exempts certain industries from the PSM standard. Why does EPA not exempt those same industries from the CAA §112(r) risk management program requirements? … HomeRead More »
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What if the quantity in the RMP Covered process fluctuates?
What if the quantity in the process fluctuates? I may not have a threshold quantity now, but I will intermittently exceed the threshold quantity. … HomeRead More »
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Worst-case release from smaller process with larger distance to endpoint
The owner or operator of a stationary source covered by the risk management program regulations must conduct a worst-case release scenario analysis as part of the required hazard assessment (40 CFR §68.25). The worst-case release is defined as the release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to an endpoint (40 CFR...
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Administrative controls considered when determining worst-case release quantity
For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity (40 CFR §68.25(b)). Why did EPA choose to allow consideration of administrative controls when...
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ISO Liquid Chlorine Tank ISO Container for Road Transport Liquid Cl2 Un1017
25-Ton Container of Chlorine dropped and catastrophic failure
Below is a video of a tragic accident that occurred today in Jordan’s Aqaba shipping port. A 25-Ton ISO Container of Chlorine (Cl2) (like the image to the left) was being lifted off a truck and onto a ship when somehow the container was dropped (too early to know the cause).  The video shows the power of a Liquified Pressurized Gas (Cl2 BP = -29F).  At this posting, there are 10 deceased...
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Sustained inattentional blindness in expert observers
This is one for all the Behavior-Based Safety Observation admirers who somehow convinced themselves their BBS process is flawless.  Most of us in the safety profession has seen the “gorilla and basketball” video.  The study used a video made famous by earlier “inattention blindness” research featured in the 2010 book “The Invisible Gorilla,” by Christopher...
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Hexane explosion in an oil extraction plant (Double Fatality - PRCS)
The accident occurred in the hexane-based rapeseed oil extraction process. After grinding the seed and obtaining meal that is then steam-cooked (100°C), pressing in a continuous screw press is used to obtain 2/3 crude oil and flakes containing 1/3 oil. This oil is extracted from the flakes in the extraction process: the flakes are transported through the extractor while a mixture of hexane and oil...
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