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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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Chlorine and a "KY Scrubber"
I have written many articles on “scrubbing NH3” in preparation for line breaks/equipment openings or emergency removal from a compromised container and with NH3 the scrubbing media is simply water (H2O).  I learned these “scrubbing” methods while working one summer in an internship and the safety pro who hired me was also an MSU graduate and he called these simple, yet...
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Finding chlorine leaks - approved methods and PSM/RMP requirements
Chlorine (Cl2) has a strong warning property: most people can detect Cl2 at approximately 0.002 ppm in air (the official odor threshold per the Agency for Toxic Substances and Disease Registry) and 0.31 ppm in water. However, most data indicate an odor threshold of 0.2-0.4 ppm. In other words, even the most minute leak will be detected by most humans, provided that your process is not allowed to run...
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Why can't I pressure my piping and hold it for X hours and if no loss in pressure it passes my test?
This is a common question we get regarding pressure testing and leak testing of process piping.  I have written quite a few posts regarding the ASME B31.3 and 31.5 requirements for pressure and leak testing over the years, but this question about holding pressure for 24-hours is one that just will not die.  I am not here to say this practice is wrong, I’m just saying it is not one that...
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Chlorine and tubing used in vacuum systems
Most of my clients who are users of Chlorine (Cl2) use it in vacuum systems where the Cl2 is being injected or inducted into a water flow.  In these smaller “processes” it is not unusual to find “tubing” being used vs. hard pipe.  It took me years to accept the tubing design model as I was always raised that Cl2 is a Category M Hazardous Material per AMSE B31 and thus...
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Could a fire in my "covered process" that did not cause a release trigger two (2) RMP requirements?
I have asked for an official interpretation on this question, but until that arrives I will answer this question as I did for a client this week.  Here is the scenario: There is a significant fire in the RMP covered.  The fire does NOT cause a release of the EHS, much less get off-site.  However, out of an abundance of caution, the local emergency response agency (Police, Fire, Sherriff,...
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LOTO on large complex machinery - LOTO specific procedures (OSHRCS)
This is a fascinating case, as the OSHRC has upheld this citation, although they significantly reduced the $ and made it “other-than-serious.” But again, I disagree with this case, as the workers appeared to have been protected during the belt change; they did not follow the LOTO procedure, which I believe was “lazily written.” This case boils down to a sprawling multi-component...
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Hazards of hydrostatic testing
OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm in that employees who performed hydrostatic testing were exposed to struck-by hazards due to the lack of specific testing procedures and training necessary to ensure personnel protection. …...
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Cl2 A kit booklet cover
The Chlorine Institute updates their Emergency Kit “A” for 100-LB. & 150-LB. Chlorine Cylinders Instruction Booklet
The Chlorine Institute has updated its instruction booklet for applying an A Kit to 100-LB. & 150-LB. Chlorine Cylinders.  Remember, these Instruction Booklets can be downloaded for FREE from their bookstore and if your facility is using 100 or 150 pound Cl2 cylinders, the A Kit is a MUST HAVE and training on the proper application of the kit to the cylinder is CRITICAL to containing a leaking...
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Work-as-Done vs Work-as-Imagined
Many safety management systems are initially developed in a theoretical environment or for ideal situations with implicit and explicit assumptions about the system’s optimal performance, equipment, and human activities. This is often called WORK-AS-IMAGINED and is formally documented in training, procedures, and equipment operating manuals. Differences between the designed performance or WORK-AS-IMAGINED...
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Does your facility include steam in its Line Break/Equipment Opening Safe Work Practice?
At 6:52 p.m. on August 10, 2020, three (3) employees attempted to remove a clog from a hydrolyzed. A hydrolyzed apparatus is used to conduct the hydrolysis reaction in starch. The employees were unable to get the steam to release from the pressure vessel. Employee #1, a senior maintenance worker, made the decision to open a flange positioned at the bottom of the pressure vessel to release the steam....
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Knowing the limitation of your respiratory protection can mean the difference between life and death
Once again, a DOT container cleaning company had another fatal PRCS incident (2020) where we have an entrant and a would-be rescuer dying in a hazardous atmosphere – oxygen deficient.  In this incident, the would-be rescuer donned a full-face Air Purifying Respirator before he attempted his rescue effort but was overcome by the atmosphere and died.  There were so many things done wrong...
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Vaneometer
A vaneometer is a MUST have for storage, use, dispensing, mixing and handling of flammable liquids
This is a very high-tech and expensive VaneometerTM.  I am kidding, it is only around $40 and it may be one of the simplest safety devices we will ever use.  But don’t let the price or simplicity fool you – it is an ABSOLUTELY CRITICAL device for those of you that have ventilation systems, especially ventilation intended for flammable vapors/gases.  Both the IFC and NFPA...
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