This incident is a tad dated (2016) but it is a perfect example of how a contractor doing work “adjacent” to a covered process can impact that process.  It is also a great opportunity to discuss how to establish the process “battery limits”.  I like to call this my “force field” around my process – NOTHING gets through the force field that is not...

Respondent owns and operates the winery facility that crushes grapes to produce wine, distilled spirits and juice for concentrate at its Facility. These products are stored prior to shipment to other facilities for further packaging and distribution. In September and November 2015, EPA performed inspections of the Facility pursuant to Section 112(r) of the, CAA, Sections 304-3 12 of EPCRA, and Section...

I recently came across some interesting RMP data from the state of North Carolina (NC), one (1) of the nine (9) states granted delegation of EPA’s authority to implement and enforce the risk management program rule.  It is only a very small percentage of RMP covered facilities, but these data and trends may be the same nationwide. In order to measure the effectiveness of the program in NC,...

As we have discussed here many many times, pressure testing of our primary containment systems for our hazardous materials is an absolute necessity to ensure the integrity of our construction/installation and/or alteration/repair.  But these tests come with some serious risks, EVEN HYDROSTATIC TESTING is a very hazardous activity.  And as shown in the OSHA investigation when things go wrong, life can...

I have written about interlocks and their design, use, and function many times.  I have also shared accidents which involved the abuse and/or misuse of interlocks.  Sadly I have another fatality to report where an interlocked guard was by-passed… At 2:20 p.m. on June 11, 2018, an employee was mixing powders using a commercial horizontal mixer. The employee was caught by the ribbon of...

OSHA recently posted a Letter of Interpretation where they reference their Compliance Directive, Inspection Procedures for the Respiratory Protection Standard, CPL 02-00-158, and the standard’s preamble in establishing the medical evaluations for “voluntary use” of negative pressure (tight-fitting) respirators.  This issue has been made clear in the CPL for years,...

Recently OSHA issued a General Duty Clause citation for “overhead process piping not properly secured causing excessive vibration” and the standard they referenced was  2007 National Board Inspection Code Part II, Section 2, Inspection 2.4.4(d) The citation was classified as “serious” and came with an $11,934 fine. … HomeRead More »

Respondent is the owner and operator of a food service distribution facility. On October 18, 2017, EPA conducted an inspection of the Facility to determine the Facility’s compliance with Section 112(r)(1) and (7) of the CAA, 42 U.S.C. § 74 12(r)(l) and (7), and the Chemical Accident Prevention Provisions of 40 C.F.R. Part 68 (“Inspection “). On May 24, 2018, EPA issued an Administrative...

OSHA has cited an asphalt paving contractor after an employee suffered fatal injuries after being pulled into an unguarded slat/drag conveyor at the company’s North Platte, Nebraska, asphalt plant. OSHA proposed penalties totaling $89,032.  OSHA cited the company for seven serious violations of machine guarding, lockout/tagout and permit-required confined space standards, including...

The business has operated a meat processing facility since 2013. The Facility uses 30,000 pounds of anhydrous ammonia in its refrigeration system at the Facility. EPA alleges the facility failed to ensure that its anhydrous ammonia refrigeration equipment complied with recognized and generally accepted good engineering practices, in violation of Section 112(r)(7) of the CAA and 40 C.F.R. § 68.65(d)(2),...

NOTE:  Another EPA RMP inspection where they took issue with the use of “ribbons” used in lieu of lockout locks!   EPA has determined that Respondent violated the Risk Management Program (RMP) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Clean Air Act (CAA), as noted on the enclosed Risk Management Plan Inspection Findings and Alleged Violations Summary...

If you stay in process safety long enough you will see some scary stuff!  It seems that “piping inspections” are become the norm these days, which after only 27 years of OSHA’s PSM standard being around I guess it is “about damn time!”.  Having grown up in the chemical industry, MI inspections were a way of life – heck I thought everyone was doing piping...