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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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Is a spiral freezer a Permit-Required Confined Space (PRCS)?
The short and simple answer is YES. It is, without a doubt, a PRCS.  This debate is much like the “Is an Evaporative Condenser a PRCS” discussion.  This week, I was presenting at the 2020 Refrigerating Engineers & Technicians Association (RETA) virtual conference, and my presentation was “Evaluating Your Ammonia Refrigeration System to determine if certain equipment...
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EPA RMP citations @ Nitrogen manufacturer (NH3 and NH4NO3 & $1.5M after 2 NH3 releases)
EPA has reached an agreement with a Nitrogen manufacturer to resolve federal civil environmental violations of the Clean Air Act’s chemical accident prevention measures and of federal laws requiring timely notification of chemical accidents. EPA identified these violations following an anhydrous ammonia release that led to thirteen workers being injured at the facility in Arizona. The facility, which...
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The Eleventh Circuit reinstates OSHA's LOTO Citation regarding a contractor death
This is SIGNIFICANT for those who truly believe in the purpose and function of OSHA’s LOTO standard.  I was never more disappointed in an ALJ than after they decided to vacate such a clear violation of LOTO.  I may have even said, “Why do lawyers/judges make for bad safety professionals.”  This fatality involved an apprentice for an electrical contractor working at...
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Wilkes Boiler
Tenth Circuit Appeals court rules a boiler connected to a PSM/RMP covered process is part of the "covered process"
After a boiler exploded at a refinery, OSHA cited the refinery’s owner for violating 29 C.F.R. § 1910.119, which sets forth requirements for the management of highly hazardous chemicals. The Occupational Safety and Health Review Commission (the Commission) upheld the violations. In doing so, it noted that the refinery had previously violated § 1910.119. But it determined that these prior violations...
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LOTO is NEVER based on how "slow it moves", even when it is 1 revolution/10 minutes
Have you ever been told… “it moves too slow to be a hazard”?  If you stay in the safety profession long enough, you will be presented with this viewpoint.  But LOTO is NEVER about how slow something moves; there is no exemption in the standard for such a thing.  Here is a case we can use to demonstrate that the speed at which a hazardous form of energy moves does NOT...
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Emergency Response Coordination Activities Effective Date(s)
The RMP Amendments finalized on January 13, 2017, included a requirement for owners or operators of a stationary source to engage in emergency response coordination activities (40 CFR §68.93).  The regulatory text in 40 CFR §68.10(b) states that compliance with these activities must be completed by March 14, 2018.  Because the RMP Amendments were not effective until September 21, 2018, are...
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Differences in accident history between Program 1 eligibility and the hazard assessment
Program 1 eligibility under 40 CFR §68.10(b) is contingent upon the process NOT having had an accidental release of a regulated substance that led to offsite death, injury, or response and restoration activities at an environmental receptor within five years prior to the risk management plan submission. Additionally, as part of the hazard assessment required under 40 CFR §68.42(a), sources are required...
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Dispersion Modeling Systems Relevant to Homeland Security Preparedness and Response
As one of its core research focuses, the U.S. Environmental Protection Agency’s (EPA’s) Homeland Security Research Program (HSRP) is interested in refining its tools and methodologies to better characterize the fate and transport of hazardous contaminants during all phases of an emergency response. Atmospheric dispersion modeling is one tool that can be used for effective emergency preparation or response...
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Ammonia Gas Cylinders Explosion
This safety alert is issued following an incident involving two explosions of ammonia gas cylinders at an ammonia gas filling and bottling plant.  The plant has been operating for more than 20 years. The ammonia stock from the suppliers will be stored first in the bulk storage tanks with a capacity of 500 and 900 tons waiting to be transferred or filled into the ammonia gas cylinders. The capacities...
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Pipe Welding and Welder Qualifications (ASME B31.1 and 31.5)
If you’re installing/repairing/modifying your chemical process piping using ASME B31.3 and 31.5, these standards have some strict QA/QA requirements for who can make the welds to join the piping.  These welders MUST be qualified in accordance with ASME Code, Section IX, “Welding Qualifications.”  ASME Code, Section IX, Part QW-103.1, states that: “Each manufacturer or contractor is...
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EPA RMP citations @ chemical facility (EtO & $38K after vessel failure and release))
At the Facility, Respondent produces, processes, stores, or handles more than 10,000 pounds of ethylene oxide. On November 3, 2019, the Glycol 2 Production Unit experienced a release of ethylene oxide.  Respondent’s Glycol 2 Production Unit experienced an ethylene oxide release involving the knockout pot D-410 of the Ethylene Oxide Scrubber Process. In response to level fluctuations in acid...
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Social Distancing Devices
COVID safety changes may need an MOC when they impact a PSM/RMP process
We have seen hundreds of changes to our businesses since March and many of these changes were needed for worker protection, but recently we came across one such change that had serious potential to cause a bad event!  Maybe you have seen the latest and greatest devices for aiding in our “social distancing” efforts.  These devices appear to be marketed towards office and healthcare...
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