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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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ASME B31.3 and Hydrostatic Relief Valves
These little safety devices cause such big troubles because of pure ignorance.  I continue to have silly debates with very smart people about meeting the absolute bare minimums from so many different recognized and generally accepted good engineering practices (RAGAGEPs).  As of today, I have written about Hydrostatic Relief Valves 84 times.  This week, I am back in my process safety...
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Houston BC
Houston BC Pellet Dryer Explosion (Technical BC)
On November 25, 2020, an explosion and fire occurred at an industrial facility in Houston BC. The facility utilizes a system incorporating a large natural gas-fired air heater to dry wood fiber material for the purpose of wood pellet production. The facility had recently been experiencing issues with operating conditions with the dryer system. The system was producing abnormal temperature spikes, irregular...
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learning pyramid2
The learning pyramid... what works best
As safety professionals, we typically spend a great deal of time training workers.  However, the time we are given to conduct this training is shrinking; so we need to be SMART in how we develop our content AND deliver it.  The “learning pyramid” has been around as long as I have been alive and it is very accurate.  The earliest such representation is believed to originate...
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Incorrect set point of LPG hydrostatic relief valve leads to explosion
A forklift operator at an industrial site was filling a liquid propane cylinder on the forklift and also heard a hissing sound. The operator then started the forklift and a flash fire explosion occurred at the forklift and propane dispensing system. The facility is an industrial wood processing plant with a propane dispensing system. Propane-fuelled forklifts are used at this facility for the movement...
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How long should fire watches keep watch after Hot Work ends?
This question is one that gets a lot of attention and the debate can become heated.  OSHA’s minimum standard, written in 1974, requires the fire watch to be maintained for 30-minutes after completion of welding or cutting operations.  But in the past decade, many insurers and standards that are more up-to-date are now requiring that fire watches be maintained for 1-hour. 1910.252(a)(2)(iii)(B)...
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New York State Department of Environmental Conservation issues citations @ chemical/plastics manufacturer (Styrene & $322K)
New York State Department of Environmental Conservation (DEC) announced the execution of two Orders on Consent with SHPP US, LLC, (known as “SABIC”), in Selkirk, including $322,400 in penalties and required facility improvements. These enforcement actions resolve violations after a September 2020 incident at the SABIC plastics manufacturing facility that released approximately 22,057 pounds...
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