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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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RMP applicability for a process at a facility connected to another facility by piping
The definition of a process would seem to say that my process is part of the larger company’s process because they are interconnected. Why can’t the larger company just include my process in its RMP? … HomeRead More »
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Ammonia present in ammonium hydroxide and RMP TQ Determination
Must a stationary source owner or operator consider the amount of ammonia present in ammonium hydroxide that is contained in a process when determining whether the threshold for ammonia is exceeded? The list of regulated toxic substances at 40 CFR Section 68.130 includes BOTH “ammonia (anhydrous)” and “ammonia (conc 20% or greater)” but does not include a specific listing for...
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Does EPA's RMP provide an exemption for the atmospheric storage of flammable liquids?
Under OSHA’s Process Safety Management Standard, an exemption is provided for the atmospheric storage of flammable liquids. Why has EPA decided NOT to include this exemption under the risk management program regulations? … HomeRead More »
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Once again EPA attempts to explain their CONCENTRATION QUALIFIERS concept
I have written often about this topic and it is without a doubt the most questioned/challenged topic in my 5-Day Advanced Process Safety course.  Several toxic substances are listed as regulated substances under 40 CFR §68.130 with CONCENTRATION QUALIFIERS (e.g., “conc 37% or greater”).  The four(4) regulated substances that have concentration qualifiers are: Ammonia (conc 20%...
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The UK's HSE Team and Developing process safety indicators
The wonderful team of process safety engineers “across the pond” in the UK have published an EXCELLENT and MUST READ guide on how a business can develop their process safety LEADING indicators.  This is a MUST READ for those PS Leaders who are looking for ideas on what and how to measure PSM/RMP Leading Indicators.  The guide methodically teaches the reader how to go about identifying...
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Figure 1 A new 2.5 inch combined pressurevacuum relief valve
Modications to pressure/vacuum relief devices allows for catastrophic failure of container
HAZMAT containers used for flammable, corrosive, and toxic liquids and gases will have a pressure/vacuum relief valve to prevent damage to the tank from changes in the internal pressure. These valves MUST be inspected and maintained in line with the manufacturer’s instructions.  Some valve designs require a special tool to dismantle them for servicing. Investigations by HSE found a technician...
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hv oil circuit breaker
Improper cleaning and lubricating breakers leads to explosion
Investigation into an explosion of a High-Voltage (HV) circuit breaker indicated that recently carried out maintenance may have been a causal factor. The incident resulted in catastrophic failure of the HV circuit breaker leading to fire/explosion and could have resulted in fatal injuries. Maintenance of HV and LV circuit breakers typically involves both the cleaning and lubricating of the operating...
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The "Pit Crew" of the business
Way back in my day as a site safety manager, one day I had a knock-down-drag-out with the facility maintenance manager regarding overdue piping inspections.  It was not long before my Plant Manager stopped by for a chat.  Apparently, the maintenance manager was not too happy having the lowly safety manager expect him to carry out the MI inspections per the plan and passed on his displeasure...
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OSHA's new "Emergency Response" standard and its HAZWOPER std
If you deal with emergency planning and response to releases of hazardous substances you can take a deep breath and have a sigh of relief… OSHA is NOT touching its HAZWOPER standard under its proposed revision to its emergency response standards.  The changes OSHA is proposing will apply ONLY to its Fire Brigade standard, 1910.156.  OSHA’s potential Emergency Response standard could...
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FM Global completely re-writes the Engineering Data Sheet 7-78 Industrial Exhaust Systems
As you know, I am a huge fan of the FM Global Data Sheets and I still recommend them to all my clients.  If your business is too cheap to buy RAGAGEPs, these Data Sheets are by far your next best options as they are FREE.  And in some situations, I actually prefer the FM Data Sheets over the expensive RAGAGEP!  Today, FM Global released their revised 7-78 Industrial Exhaust Systems....
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OSHA's proposed Fire Brigade/ER standard - Part II
Who might be covered by a new Emergency Response standard? The draft Emergency Response standard would apply to employers that mitigate a hazard in an emergency response situation and the activity is currently covered by 29 CFR 1910.156, or is not covered by another OSHA standard. The standard would apply to, but not be limited to, entities that provide one or more of the following services as a primary...
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OSHA's proposed Fire Brigade/ER standard - Part I
Have you seen OSHA’s proposed ER standard?  It will replace 1910.156 and encompass all aspects of emergency response, such as firefighting, fire rescue, emergency medical service, technical rescue (rope/high angle, cave, etc.), vehicle/machinery rescue, water rescue/recovery (land/shore-based, Swiftwater, underwater), search and rescue (urban, mountain, wilderness).  I have gone through...
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