Lesson’s learned:  A WRONG CHEMICAL – WRONG TANK incident produced a chlorine release and brought EPA to the facility.  The EPA inspection does not appear to have looked at the Cl2 incident, but rather stayed focused on the propylene oxide process – their “covered process”.  As well, in March of this year both the facility and the trucking company involved...

Respondent operated an agriculture retail facility and receives, stores, and sells anhydrous ammonia. On or about June 19, 2018, representatives of the EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that the facility had ammonia storage capacity consisting...

Respondent operated an agriculture retail facility and receives, stores, and sells anhydrous ammonia. On or about June 19, 2018, representatives of the EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that the facility had ammonia storage capacity consisting...

A few years ago I posted a fatal incident involving unloading NH3.  The driver made a valving error and left the liquid bleed valve to a plastic tote open while he was transferring liquid NH3 to the storage tank.  He was standing ~6-10′ from the tote when it violently ruptured when the liquid NH3 entered the warm water.  He did not die of traumatic injuries – he did from...

A few years ago I posted a fatal incident involving unloading NH3.  The driver made a valving error and left the liquid bleed valve to a plastic tote open while he was transferring liquid NH3 to the storage tank.  He was standing ~6-10′ from the tote when it violently ruptured when the liquid NH3 entered the warm water.  He did not die of traumatic injuries – he did from...

Many of us may not be able to understand the commentary unless you speak Spanish/Portuguese, but watch how this drill is managed!  For those who are “Incident Commanders” watch all the different functions that are being managed simultaneously in the HOT and WARM zones!  And remember, this is a “drill” – in a real incident the staging and landing areas would be...

Many of us may not be able to understand the commentary unless you speak Spanish/Portuguese, but watch how this drill is managed!  For those who are “Incident Commanders” watch all the different functions that are being managed simultaneously in the HOT and WARM zones!  And remember, this is a “drill” – in a real incident the staging and landing areas would be...

Here is a look at OSHA’s Process Safety Management (1910.119) compliance activity during the period of October 2018 through September 2019. As you can see, OSHA issued 263 citations from 76 inspections for a total of $2,732,232 in fines.  Here is a quick breakdown of activity: … HomeRead More »

Here is a look at OSHA’s Process Safety Management (1910.119) compliance activity during the period of October 2018 through September 2019. As you can see, OSHA issued 263 citations from 76 inspections for a total of $2,732,232 in fines.  Here is a quick breakdown of activity: … HomeRead More »

This week we saw OSHA issue a $1.5M citation after an explosion killed four workers at a silicon chemical products manufacturer.  All of the citations were classified as Willful and all were related to using equipment that was not approved for a hazardous location (HAZLOC).  This week I was working with a client doing a PHA that involved heating the batch(s), which contained Class IIIB combustibles,...

This week we saw OSHA issue a $1.5M citation after an explosion killed four workers at a silicon chemical products manufacturer.  All of the citations were classified as Willful and all were related to using equipment that was not approved for a hazardous location (HAZLOC).  This week I was working with a client doing a PHA that involved heating the batch(s), which contained Class IIIB combustibles,...

I usually breakdown the OSHRC decisions in a technical way; however, this one is more cultural rather than technical.  It is a story of a chicken processing business that decided that a Safety Professional’s job could be shared by others and they could save the $ on the salary.  This is a company that already had a history with OSHA compliance issues and their decision to hire a contractor...