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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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EPA issues RMP citations @ water treatment facility (WRONG CHEMICAL - WRONG TANK incident, 2,000 lb Cl2 release & $66K)
Chlorine, CAS No. 7782-50-5, is an extremely hazardous substance regulated and listed in 40 C.F.R. § 68.130. As the owner and operator of a stationary source, with respect to the use and storage of ferric chloride and sodium hypochlorite, Respondent has a duty under the General Duty Clause, Section 112(r)(1) of the CAA, to design and maintain a safe facility taking such steps as are necessary to prevent...
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EPA issues RMP citations @ poultry processing facility (NH3 & $124K)
The Respondent processes and freezes poultry products for distribution. The Respondent has two systems which include Anhydrous Ammonia at the Facility. The Respondent had one RMP program level 3 covered process (anhydrous ammonia refrigeration systems) which store or otherwise use a regulated substance in an amount exceeding the applicable threshold. The Respondent’s poultry freezing processes...
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Cal/OSHA Cites Four Employers $1.75 Million for Safety Violations in Death of Worker at a refinery
The Cal/OSHA Process Safety Management Unit has cited a refinery and three contractors a combined $1,753,375 for serious safety violations following a confined space death of a 35-year-old worker who suffocated in a regenerator overflow well. Cal/OSHA inspectors cited three of the four employers with willful and serious violations after determining that they failed to follow confined space regulations,...
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Hierarchy of Excuses
The Hierarchy of Responses, How Hazards Sink to the Bottom
I am not sure who came up with this, but it is a classic example of far too many organizations. … HomeRead More »
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The Safety Process through the eyes of a Quality Assurance Process
As many of you know I have taken on a new client (full time) in 2022 and my role in this organization is to build a safety management system (SMS).  And let me tell you what, if you thought explaining a RAGAGEP to management was difficult – try explaining that safety is a “process” and an SMS should function just like a QA/QC process in a business.  I have written several...
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EPA issues RMP citations @ chemical manufacturing facility (Cl2, CHCl3, CH3Cl, C2H3Cl & $500K)
The respondent is the owner and operator of a chemical manufacturing facility. EPA conducted an inspection of the Facility on May 1-4, 2018, to determine the Respondent’s compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. The following chemicals are “regulated substances” pursuant to 40 C.F.R. § 68.3. The threshold quantity for the regulated substances, as listed in...
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EPA issues RMP citations @ ice-making plant (NH3 & $170K)
Respondent owns and operates an ice-making plant that uses anhydrous ammonia in a refrigeration “process”. In 2016, Respondent filed a Program 3 RMP for the Process and reported that it used 22,000 pounds of anhydrous ammonia. In accordance with 40 C.F.R. § 68.10(a) and (f)-(h), the Respondent’s use, storage, and handling of anhydrous ammonia in the Process are subject to the requirements of RMP Program...
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EPA issues RMP citations @ warehouse (Flammables & $109K)
Respondent is a limited liability company that operates as a public warehousing facility.  The term “have a general duty in the same manner and to the same extent as section 654 of title 29 [of the U. S. Code]” means owners and operators must comply with the General Duty Clause in the same manner and to the same extent as employers must comply with the Occupational Safety and Health Act (“OSH...
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Understanding your Pressure Vessel(s) "Birth Certificates"
I like to explain the documentation for our pressure vessels much in the same context as our birth certificates.  For every pressure vessel in service today, we must have that vessel’s U-1 Form.  And please don’t tell me about the OSHRC decision stating otherwise.  I really don’t care what a group of lawyers think about how I manage my process hazards.  In other...
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HF in root cause analysis
Human Factors 101... causal analysis
We are working to implement a formal root cause and corrective action process for a client. The industry has a very different view and approach to what I have come to know over the last 30 years as Human Factors. I think my friends “down under” are reading my mind or my articles at SAFTENG these past couple of months. One of my favorite experts in HF has posted one of his best pieces of work on the...
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Heiarchy of Controls and the "Elimination and Falls"
As we approach The National Safety Stand-Down To Prevent Falls in Construction (May 2-6, 2022) I am reminded of how some view “Elimination” within the Hierarchy of Controls.  The number of postings on social media calling for the “Elimination of falls” in the construction industry has me asking… can this actually be done?  One such proposal calls for roofs to...
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Pressure Vessel "Car Seal" program in Saskatchewan
In the USA we use ASME Section VIII, Appendix M-5, and the National Board’s Part 4 when we need to install a block valve before or after a relief valve (RV).  In Saskatchewan, Canada their safety authority has a program titled “Pressure Relief Path Stop Valve Control Program“.  It is a really nice start to develop a “car seal program”.
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