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Secondary container labeling, GHS Pictograms, NFPA 704, HMIS, and the dead horse!
It seems that just about every month, even during the COVID Pandemic, we come across a safety professional, 3rd party auditor, and even an OSHA CSHO who will swear on his/her grandmother’s grave that the ONLY acceptable HAZCOM labels in the workplace are those that contain: Product identifier; Signal word; Hazard statement(s); Pictogram(s); Precautionary statement(s); and, Name,...
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A food pantry, 50% Hydrogen Peroxide, and DHS's CFATS
Today a longtime friend and SAFTENG member shared an article in our FaceBook group regarding a food pantry in TN that accidentally gave out fifty-four (54) 1-gallon containers of 50% Hydrogen Peroxide (H2O2) in their food packages.  Now I have no idea what a food pantry is doing with 50% Hydrogen Peroxide, much less that quantity.  I write a lot about OSHA’s PSM and EPA’s RMP...
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EPA RMP citations @ refrigerated distribution facility (NH3 & $11K)
NOTE: I have posted this inspection because of the level of detail the inspectors went.  There has been a significant shift in the quality of findings from BOTH OSHA and EPA in their process safety inspections.  This EPA inspection team was well aware that the IIAR Bulletins are being phased out and replaced with ANSI/IIAR standards.  The amount was low, but things could have been much...
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Hotwork Fires and Explosions (1998-2018; 589 pages of HW incidents)
NOTE: these are all my Hotwork / Welding related incidents from 1998-2018 Incident Alerts.   You can use your browsers “page search” function to search for specific keywords if you are looking for a specific type of accident.  MANY of the links no longer work, but I always tried to capture the gist of the incident in my summary. I have always tried to scrub company names from these reports...
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EPA RMP citations @ poultry processing facility (NH3 & $104K)
Respondent operates an ammonia refrigeration system which uses 30,345 pounds anhydrous ammonia (ammonia). Respondent has one RMProgram level 3 covered process, which stores or otherwise uses an extremely hazardous substance in an amount exceeding its applicable threshold of 10,000 pounds. On December 21, 2017, the EPA conducted an onsite inspection of the RMProgram related records and equipment for...
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OSHA grants an interim order for isolation of a "condenser/water box" (PRCS isolation - 1910.146(d)(3)(iii))
CAUTION:  This interim order is specific to the facility requesting it.  Do NOT use these measures at your facility!!! If I had a nickel for every time I have heard the excuse… “its more dangerous to do these isolations than it is to do the entry with lesser isolations,” I would not be writing this article instead, I would be on my yacht deep-sea fishing somewhere off the...
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CNC door interlock bypassed (Fatality & $70K Willful)
At 7:00 p.m. on December 4, 2019, an employee was working at a machine shop. He was operating a CNC (computer numerical control) lathe to machine material. The machine was equipped with an interlock system.  The interlock system was supposed to prevent the lathe from functioning if its door was open; however, the interlock system had been bypassed. The narrative did not say who had performed this...
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EPA RMP citations @ meat processing facility (NH3 & $156K)
Respondent is the owner and/or operator of a meat processing facility that uses, handles, and/or stores more than a threshold quantity of anhydrous ammonia. Respondent is required to prepare and implement an RMP to detect and prevent or minimize accidental releases of such substances under section 112(r)(7) of the CAA. Respondent meets the Program 3 eligibility requirements under 40 C.F.R. § 68.10. ...
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Aircraft/fuel truck collision highlights importance of following safety directives during emergencies (TSB of Canada)
The Transportation Safety Board of Canada (TSB) has released its investigation report (A19O0063) into the May 2019 collision between a fuel truck and a plane at Toronto/Lester B. Pearson International Airport, Ontario. The investigation highlights the importance of passengers familiarizing themselves with safety information and following instructions from flight attendants during emergencies. On 10 May 2019,...
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Listings of Chemicals Likely to Undergo Self-Polymerization (DOT ERG = P)
The DOT ERG identifies chemicals as being shipped “inhibited” or “stabilized” and have a “P” listed with their guide number meaning that the chemical can polymerize. These inhibitors are TIME and TEMPERATURE dependent! The inhibitors can be tested and more inhibitor added if necessary, albeit VERY RISKY once the reaction has begun AND the fact that these inhibitors are not something First Responders...
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A PHA is not a JHA; a JHA is not a PHA
Both of these tools are necessary in the process safety arena; however, they have very different and distinct roles in process safety management.  In my career I found it best to perform the PHA first and based on the deviations identified in the PHA, we would write our SOPs to cover those deviations.  And of course, every SOP gets written from a JSA/JHA.  It works like this…...
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Differences between a BLEVE and a HIT (2020 & 2024 ERG)
UPDATED on 4/4/24 with 2024 ERG Info   This week we saw the official release of the 2020 Emergency Response Guide (ERG) from DOT/PHMSA and along with this 2020 update came some clear distinctions between a “Heat Induced Tear” (HIT) and a Boiling Liquid Expanding Vapor Explosion (BLEVE). (emphasis by PHMSA) A Heat Induced Tear (HIT) is a rupture of a NON-PRESSURE tank car containing...
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