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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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OSHA publishes its Heat Initiative: Inspection Guidance
In a memorandum to Regional Administrators, OSHA establishes an enforcement initiative to prevent and protect employees from serious heat-related illnesses and deaths while working in hazardous hot indoor or outdoor environments.  It expands on the agency’s ongoing heat-related illness prevention campaign by setting forth the enforcement component and reiterating its compliance assistance and...
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EPA issues RMP/EPCRA ENFORCEMENT ALERT: "Risks of Improper Storage of Hazardous Chemicals at Chemical Warehouses and Distribution Facilities"
Some chemical warehouses and distribution facilities may be failing to properly manage hazardous chemicals as required by federal law. In the past several years, the EPA has visited numerous chemical warehouses and distribution facilities (i.e., companies that process, formulate, blend, re–package, store, transport, and market chemical products) to determine compliance with the Clean Air Act...
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EPA is adding natural gas processing (NGP) facilities to EPCRA/TRI
EPA is adding natural gas processing (NGP) facilities (also known as natural gas liquid extraction facilities) to the scope of the industrial sectors covered by the reporting requirements of the Emergency Planning and Community Right-to-Know Act (EPCRA), commonly known as the Toxics Release Inventory (TRI), and the Pollution Prevention Act (PPA).  … HomeRead More »
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Group E (Metal Dusts) only have Div 1 locations (NFPA 499)
An old dog is never too old to learn something new. NOTE: This clarification was made in the 2021 edition of NFPA 499. In NFPA 499, the definition of a Class II, Div 1 HAZLOC is as follows: (emphasis by me) … HomeRead More »
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Will OSHA's new "Emergency Response" standard establish Engine Company staffing levels?
As discussed, OSHA is making significant revisions to its Fire Brigade standard.  And in the DRAFT version, OSHA establishes a minimum staffing level for working/entering an IDLH atmosphere.  Many of you who are part of or manage the fire brigade may recall that OSHA has made room for “judgment” regarding staffing available and performing life-saving operations.  In fact,...
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OSHA's new "Emergency Response" standard and responder medical/fitness requirements
This provision of the draft standard would, based on the type and level of service(s) established by the Emergency Service Organizations (ESO), require the ESO to establish minimum medical requirements based on the tiers of responder duties, tasks, and responsibilities. A qualified healthcare professional would perform the medical evaluation of the responders. The medical evaluation would include a...
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Does Double Block and Bleed require INDEPENDENT isolation points?
In the 90s, I was working a turn-around at a sister facility and learned the niftiest trick related to Double Block and Bleed (DB&B).  When the isolation valves and the bleed valve were nearby (i.e., a couple of feet or less) of each other, they would use just a single lock to secure the isolation.  They would use a LOTO cable to pass through all three (3) lockout devices, with the isolation...
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Technical Analysis: The Risks of Pneumatic vs. Hydrostatic Testing
A catastrophic incident at an engineering facility serves as a definitive case study in the dangers of improper pressure testing. A technician suffered life-altering injuries when a 335-liter (88-gallon) vessel exploded during a pressure test. The root cause was a fundamental failure in hazard control: the company opted to use compressed air (pneumatic testing) instead of water (hydrostatic testing)...
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EPA issues RMP citations @ "new" meat processing facility (NH3 & $87K)
Respondent owns and operates an ammonia refrigeration system at its meat processing facility which began operation in February 2019. The ammonia refrigeration system had an initial charge of 17,000 pounds of anhydrous ammonia when operations began, making the facility subject to requirements of Chemical Accident Prevention Provisions in accordance with 40 C.F.R. § 68.10(a) and the requirements of Program...
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OSHA's proposed Emergency Response/Fire Brigade standard would not apply to all public sector emergency responders
The proposed OSHA standard will NOT apply to all public sector emergency responders. The scope is limited to Emergency Service Organizations (ESOs) and responders under OSHA’s jurisdiction. ONLY public ESOs that are in state plan states are under OSHA’s jurisdiction and therefore the analysis excludes public ESOs and responders in non-state-plan states. The following states and territories have state...
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EPA finally answers the question: Are "tube" trailers considered a single process?
This has been a huge battle in the power generation and semi-conductor industries!  To me, it is very clear – as soon as the trailer is “dropped”, meaning the semi that was pulling the tube-trailer has been detached, then that trailer becomes a “stationary process”.  EPA has several documents making this point and for those who visit my PSM/RMP Case Page you...
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Can the RMP's partial pressure exemption be applied to formaldehyde solutions?
Formaldehyde is not specifically listed with a concentration cutoff, but is listed with the QUALIFIER “solution”. Can the partial pressure exemption be applied to formaldehyde solutions? … HomeRead More »
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