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EEBAs and their inspection and maintenance schedules and requirements
Several of the EEBA manufacturers do not offer this advice upfront, but some manufacturers put this info in their owner’s manuals.  I am no lawyer, so I have no idea why a manufacturer would NOT provide this information for an Emergency Escape Breathing Apparatus (EEBA).  But having these devices in the workplace, if you use one of these brands, the facility’s RP must cover this...
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EEBAs and their limitations
What is the number 1 battle we deal with in our respirator programs?  Facial hair!  But luckily an Emergency Escape Breathing Apparatus (EEBA) is not hindered by facial hair; however, an EEBA could be hampered by… … HomeRead More »
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EEBAs... Do you know just how far they will get you?
Emergency Escape Breathing Apparatus (EEBA) are making come back – at least I am finding more and more facilities that never had them now implementing them for many reasons.  Some companies now believe they are required because of PSM/RMP, some 3rd party PHA facilitators must be getting kick-backs as a lot are recommending them in their PHA’s, and I have even seen OSHA negotiate their...
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LOTO cable
Lockout with cable/shark leader and identifying the isolation device is under LOTO control
The client has approved this posting as they want to make sure others can learn from their incident.  PLEASE discuss this incident with your teams if your LOTO practice(s) resemble theirs –  what they did was VERY COMMON and I teach this method in all my LOTO courses at process plants.  I have revised my training and written program as a result of this incident, and I hope many...
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EAPs and Procedures to be followed by employees who remain to operate critical plant operations before they evacuate (1910.38(c)(3))
If there is one common finding in our PSM/RMP audits it is this single requirement for employees who remain to operate critical plant operations before they evacuate.  And when we attempt to explain what is actually necessary to just meet 1910.38(c)(3) we are oftentimes met with downright hostility.  It is rare these days that anyone needs to stay behind, but I would say about 25% of the...
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EPA EPCRA/CERCLA citations @ vegetable oils and fats facility (NH3 release & $36K)
Section 304(a) of EPCRA and the regulations found at 40 C.F.R. Part 355, Subpart C, require the owner or operator of a facility at which a hazardous chemical is produced, used or stored, to immediately provide notice to the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC) as described in Section 304(b) of EPCRA, when there has been a release of an EPCRA extremely...
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Which RMP facilities must develop an Emergency Response Program?
The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which must include an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date. Do all facilities subject to the risk management program...
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Can the partial pressure exemption be applied to formaldehyde solutions?
Formaldehyde is not specifically listed with a concentration cutoff, but is listed with the qualifier “solution”. Can the partial pressure exemption be applied to formaldehyde solutions? … HomeRead More »
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Types of Information Relevant for Response Planning (RMP 68.93(b))
The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency planning and response organizations...
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EPA RMP citations @ Chlor-alkali manufacturer (Cl2 & $87K)
On August 18, 2018, the EPA issued to Respondent a Notice of Potential Violation (“NOPV”), providing notice that the EPA found that Respondent had potentially committed the alleged violations described in Section V of this Agreement and providing Respondent an opportunity to confer with the EPA. On February 14, 2019, representatives of Respondent and the EPA discussed the August 18, 2018, NOPV. ...
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ERG 2020 Mobile App is now available
The Pipeline and Hazardous Materials Safety Administration (PHMSA) has developed a free, mobile web app of its Emergency Response Guidebook 2020 (ERG). The new safety tool provides the nation’s emergency responders with fast, easily accessible information to help them manage hazardous material incidents. This software is available from the Apple iTunes store for iPhone, and from the Google Play...
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Process Safety and our primary containment systems
A wise plant manager told me this in my first year in the petrochem industry.  I am paraphrasing When it comes to our primary containment systems (he was speaking to piping in this discussion) – if it is not done darn near perfect, all we have to do is wait a while and bad things will just begin happen.  But when it is done darn near perfect (as required by ASME B31.3) AND we have the...
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