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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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Ammonia refrigeration and process chemistry
Over the years I have been told time and time again that there are two absolutes in ammonia refrigeration.  #1 – we do not have “temporary operational conditions” so we have no need for “temporary operating procedures” and #2 – there is no “process chemistry” in ammonia refrigeration.  But it dawned on me this week that I had beaten the “temp...
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Understanding the differences in a NIOSH 14G and 23C approvals
Last week I mentioned a trade group was planning to implement a standard/guide (not sure how it will be classified) that will suggest that the industry should use respirators that carry a NIOSH 14G approval rather than the more common 23C respirator.  Since all of this has been happening I have received numerous e-mails, calls, and texts asking me “what the heck is the difference”...
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The difference between an RMP Correction and Update and the six (6) changes that will trigger an Update
RMPs must be updated at least once every five years. EPA offers a  Checklist for Submitting your Risk Management Plan (RMP). We must fully update your RMP for resubmission sooner than the five-year anniversary date if any of these changes occur: … HomeRead More »
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Technical BC launches Ammonia Safety Awareness Program
The Ammonia Safety Awareness Program was developed due to the rise of ammonia-related incidents and hazards over the past few years, including the tragedy at Fernie Memorial Arena.  Developed in collaboration with industry professionals, this program provides training and downloadable tools to fill in knowledge gaps and share best practices for maintaining ammonia refrigeration equipment...
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Did Technical BC just say pressure vessels in NH3 refrigeration need to be PWHT?
This topic has always been one that seemed to be controversial in the ammonia refrigeration sector, with decades of denial that Stress Corrosion Cracking could occur in an ammonia refrigeration process due to the water content in the ammonia.  But last month, Technical BC (British Columbia) discussing their SCC concerns related to pressure vessels in a refrigeration process. I know, that ammonia...
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EPA addresses the forever on-going debate about revised RAGAGEPs and the facility's responsibility to upgrade
One of the biggest and longest debates in process safety circles is the responsibility of businesses to upgrade their process design(s) based on an updated RAGAGEP.  OSHA attempted to address this in a 2016 LOI.  Now EPA has stated their “official position”… (emphasis by me) … HomeRead More »
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EPA issues RMP citations @ fluoroproducts facility (Oleum and HF & $205K)
The Respondent owns and/or operates a chemical manufacturing facility that uses: A. Oleum (fuming sulfuric acid) [sulfuric acid, mixture with sulfur trioxide] (“Oleum”); B. Hydrogen fluoride/hydrofluoric acid (cone 50% or greater) [hydrofluoric acid] (“Hf “). in a fluoroproducts process and a sulfuric acid process.  From August 28 – 31, 2018, EPA conducted an inspection...
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EPA RMP GDC citations @ Ammonia plant (NH3 & $39K)
The Facility is a nitrogenous fertilizer manufacturing facility that produces anhydrous ammonia, urea solutions, urea-ammonium nitrate, and by-product gaseous carbon dioxide. The Facility also produces intermediates (including nitric acid and ammonium nitrate solution) during the manufacture of the above products. Based on the quantity of anhydrous ammonia present at the Facility, the Facility is subject...
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What constitutes an emergency response or incidental release of anhydrous ammonia
OSHA updated a 2017 Letter of Interpretation in January 2021 and it is causing quite a stir in the anhydrous ammonia (NH3) fertilizer industry and could have impacts on other industries that use NH3.  In this revised LOI, OSHA states… … Therefore, OSHA believes it is possible, and indeed likely, that any given release of anhydrous ammonia in your scenario will necessitate an emergency...
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As a profession we should agree to hate "half-truths"
I just finished reviewing a draft document that a trade group will be asked to vote to sanction the document as it relates to emergency escape respirators.  There was a lot of talk about requiring these escape respirators to carry the NIOSH approval of 14G (vs. the more traditional 23C style respirator).  There is talk that a respirator with a NIOSH 14G Approval can be used as an escape respirator...
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On your next RMP 5-year Update, be sure to include this
At least every five (5) years a Risk Management Plan must be updated.  We are seeing a lot of RMP that have been updated in the past 12-16 months that failed to include this in their update.  I wrote about this new requirement this past weekend, but now I want to demonstrate the “fall-out” from this new rule and how it should be reflected in our RMP Update(s). … HomeRead...
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Have we updated our EAP and/or ERP to ensure compliance with 40 CFR Part 1604?
Back in February, I broke down the Chemical Safety Board’s new Chemical Incident Reporting Rule (40 CFR Part 1604) and since then we have conducted quite a few safety reviews, emergency response training sessions, and PSM/RMP audits and so far we have not found a single facility that has updated their Emergency Response and/or Emergency Action plans by adding the CSB to their “reporting...
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