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What RMP information will be available to the public under the new RMP Reconsideration Final Rule
Under the final RMP Reconsideration rule, members of the public can continue to obtain access to RMPs through three different means: Read-only access to the full version of facility RMPs at reading rooms by appearing in person at a Federal reading room; Read-only RMP access directly from the local emergency planning committee in the location where the person lives or works; or Submitting a FOIA request...
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RMP Reconsideration Final Rule is FINAL as of November 20, 2019
On November 20, 2019, EPA finalized changes to the Risk Management Program (RMP) Reconsideration final rule to better address potential security risks, regulatory consistency and reasonable consideration of costs. The changes are intended to promote better emergency planning and public information about accidents and maintain the trend of fewer significant accidents involving chemicals regulated under...
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Tanker welding fatality 2019
ANOTHER fatality from welding on Tanker Truck with vapors
This one occurred in South America but due to the sheer power of this event, I am sharing with the SAFTENG membership.  The worker was thrown over 650 feet and of course, perished in the accident.  Its the same old story… tanker starts to leak – they take to a repair shop for repair – repair shop does NOT prepare the tanker properly and begins welding on it and… BOOM! ...
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CAT Failure NH3
Another CATASTROPHIC FAILURE of a Ammonia Refrigeration vessel (150-gallon Vessel @ chicken slaughterhouse)
We have had another catastrophic failure of a pressure vessel used in an ammonia refrigeration process and this time we caught it on camera.  The event occurred last week and unfortunately, I have not heard of any causes or if anything special was happening within the process when this failure occurred.  This picture shows us part of the small vessel lying in the area of the failure. ...
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Respiratory Protection Program and Records Retention
For those of you who are SAFTENG members and manage a Respiratory Protection program, this is NOT news to you, as we have discussed this many times before, and if you have been to my 1.5 Day Respiratory Protection Administrator course, you got this beat into your head!  But for those less fortunate, here is the official OSHA position… The respirator program MEDICAL evaluation is indeed a...
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For the love of life... LABEL your vessels that utilize an inert gas!
We are all accustomed to labeling our process vessels/tanks with the contents; many of us that operate batch processes even use some specialized labeling and cross-referencing hazard data based on the batch being run.  But one item too many of us fail to identify within a vessel is the use of an inert purging/blanketing gas such as Nitrogen.  This year a facility had a very serious incident...
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SCANNER AUDIO: At Least 37 Hospitalized After Anhydrous Ammonia Spill [Beach Park, IL]
The call came in as a “vehicle fire”… Listen and Learn… … HomeRead More »
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EPA RMP GDC @ refrigerated food distribution warehouse (NH3 & $101K)
At all relevant times, Respondent owned and operated a refrigerated food distribution warehouse with an ammonia refrigerant system which contains approximately 9,617 pounds of ammonia. EPA inspected the facility on August 9, 2018. Prior to the August 9, 2018, inspection, Respondent had not performed a hazard analysis nor developed standard operating procedures for the ammonia refrigerant system. ALLEGED...
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A PSSR is NOT an Initial Start-Up Procedure
I am not sure where or quite when this vicious rumor began, but let’s make this clear: A Pre-startup Safety Review (PSSR) is an ENTIRELY separate exercise AND MUST be completed BEFORE the Initial Start-Up procedures are implemented. Granted it may be the same personnel doing both tasks, but the PSSR is FULLY COMPLETED BEFORE the Initial Start-Up procedure begins.  In fact, the PSSR MUST...
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Personal Fall Arrest System or Ladder Safety System on Fixed Ladders (OSHA LOI)
Scenario: In an industrial setting, a ladder starts 100 feet above grade on the side of a tower. The base landing of the ladder is only there for ladder access, so it meets OSHA minimum dimensions and is equipped with standard guardrail. The length of climb above this base is no more than 24 feet. Question 1: What are the requirements for this elevated ladder with regard to falls? Does this scenario...
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Definition of Confined Space, as it may apply to large product heating and aging furnaces (OSHA LOI)
Background Product parts are heated in the furnaces using natural gas to temperatures ranging from 700ºF to 2200ºF to facilitate material processing. The furnace doors are actuated remotely from either the cab of a forklift or a control panel. Parts are loaded and unloaded from the furnaces using forklifts during production runs. The furnaces range in size from 8 feet x 8 feet x 8 feet to 18 feet x...
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Personal Fall Arrest System or Ladder Safety System on Fixed Ladders, and Fixed Ladders Used on Grain Silos for Emergency Escape (OSHA LOI)
Background: Multiple sections of off-set ladders are being designed to be installed on the outside of a grain silo that is 80 feet or more in height. Rest platforms will be installed at each off-set and will be provided with guardrail systems to meet OSHA’s requirements. The rest platforms measure 3 feet by 3 feet in area. Some of the ladder sections are less than 24 feet in length. Question 1: Does...
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