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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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weld on pressure testing warning
Did WELD-ON® just mandate hydrostatic pressure testing of Chlorine piping?
I have several chlorine projects going on and a couple of them are being installed by the same contractor, one of the best contractors in the chemical industry (I wish I could name them by my CA prevents me from listing them as a client or supporter!).  They used the pandemic to get everything installed and now we are ready for our post-construction and Pre-PSSR activities, which is when we do...
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EPA issues RMP citations @ candy manufacturer (NH3 & $26K)
Respondent is the owner and/or operator of a candy manufacturing facility, which has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. At its Facility: a. Respondent produces food products b. Respondent has on-site for storage, 18,000 pounds of anhydrous ammonia c. Respondent has one RMProgram level 3 covered process,...
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welder stamp highlighted
ASME B31.3 requires each weld be identified as to who made the weld
This redneck from western KY can understand one of the most fundamental requirements from ASME B31 standards… ONLY certified welders can make the welds AND each weld MUST be IDENTIFIED as to who made the weld(s)! Now ASME gives us options for meeting the “identification” requirements (e.g., stamping or Isometric Drawings). Still, these two requirements are a MUST-have for our PSM/RMP...
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CPVC Chlorine piping and "solvent welded" connections
During my “lost years” early in my college days (i.e. before I discovered firefighting and OSH) I built swimming pools during the summers.  That job required a lot of piping work, which I got pretty good at, at least I thought I had until I got into my first Chlorine (Cl2) process as a safety engineer.  Now words mean a lot and when dealing with Cl2, DETAILS MATTER, so when I...
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NH3 pentouse 2
Is an ammonia refrigeration penthouse a Permit-Required Confined Space?
So far, I have discussed Evaporative Condensers and Spiral Freezers, making the case that most of these spaces are indeed Permit-Required Confined Spaces (PRCS).  This last space is gaining a lot of traction over the past 10-20 years, and still today, the design of most of these penthouses makes them, without a doubt, a PRCS.  In this last article in this series, I will break down the characteristics...
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OSHA issues PRCS and Willful Fall Protection citations ($234K)
A worker at a water technology company suffered an injury when a guardrail loosened and he fell and struck his head on a support beam as he lowered himself into a nearly 30-foot deep water test pit. OSHA received the report of the injury on Oct. 29, 2020. Its inspectors later determined that the company exposed employees to walking-working surfaces hazards, failed to provide employees with fall protection...
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MI OSHA Cl2 PSM 2008
Chlorine and Process Safety (MI-OSHA ppt)
This was buried in my archives by mistake until a member found it while digging through all the PowerPoint presentations.  It is from way back in 2008 when I was heavily involved in Water Treatment Plants and their use of Chlorine and the Chemical Facility Anti-Terrorism Standard (CFATS) roll-out.  The presentation was put together for a WWTP Summitt by MI-OSHA and is quite detailed as to...
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EPA EPCRA CERCLA RMP
GREAT UPDATE from EPA on RMP, EPCRA and Ammonia's impact
Monika Chrzaszcz, U.S. EPA, Region 5, presented at this years MI Safety Conference on the matters of Anhydrous Ammonia and how the chemical impacts EPCRA and RMP.  Her presentation points out some of the RMP amendments that are in place now and those coming, as well as EPCRA Tier II reporting and release reporting.
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NFPA 499 (2021) updated with a peculiar reference
NFPA 499, Recommended Practice for the Classification of Combustible Dusts and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas was updated for 2021 and this update involves a very peculiar reference that has me scratching my head.  This reference is also another example of why Safety and Process Safety professionals have come to hate RAGAGEPs and Consensus...
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EPA issues RMP citations @ paper mill (ClO2 & $32K)
It’s never a good sign when the EPA inspector is in the process and the operator’s personnel detector goes into alarm and the worried inspector is told… it was typical for the alarm to sound during sampling.  This led the inspector to inquire about this level of exposure for a repeated task such as sampling and that opened the door to three (3) SOP findings! Respondent operates...
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Opening the "bleed" on a Double-Block & Bleed arrangement is a "process opening" and is NOT to be taken lightly
We have discussed this numerous times over the years, but we rarely have a first-hand account of a “bleed” within a DB&B causing an LOPC event.  But because CALARP now has a Program 4 Incident Reporting trigger, we get to see firsthand how a 3/4″ bleeder on a 14″ pipe handling a HHC/EHS can cause a serious incident.   On October 5, 2018, a contract employee...
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CALARP Program 4 reporting
Cal ARP Program 4 and reporting on Process Safety Performance Indicators
Way back in 2017, the state of California (CA) revised it’s Accidental Release Prevention program by adding a Program Level 4 for the state’s refineries.  In addition to the expanded prevention program requirements, the refineries are required to submit investigation reports, including root cause analysis after any major incident. But the one aspect of the Program 4 changes I...
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