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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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Cl2 Relief System
Hydrostatic Relief on piping systems - why so much hate?
We visit this topic once again as I have already spent time with a “former client” who is now in a serious bind with both OSHA and EPA after a significant Chlorine (Cl2) release.  They are a former client as they fired me after a 5-year PHA and 3-year audit a number of years ago.  They hired me because of their frustrations regarding the handling of their Cl2 and their inability...
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hand sanitizer bottle
More COVID-19 safety and OSHA inspections (HAZCOM and Flammable Liquids)
This week I received a call from a client who had yet another visit from OSHA regarding COVID-19 complaints, but this time the CSHO was an experienced safety professional who peeled that onion back a few more layers and thus she was recommending a serious violation of HAZCOM related to the COVID-19 safety program.  What she found and how she found it is something all facilities should be aware...
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Grounding grids for emergency transfers of flammable liquids
Back in my HAZMAT days, we did a lot of transfers from damaged containers to proper containers to mitigate the release of hazardous materials.  When the HAZMAT was a flammable liquid, we oftentimes had to construct our own grounding grid.  This was more than not a massive challenge for us as we did this all over North America and the soils differ immensely depending on where we were operating...
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Addressing Hazardous Area Electrical Installations (USCG)
The United States Coast Guard (USCG) has issued a Safety Alert to emphasize the importance of properly installed and maintained listed or certified safe electrical equipment in hazardous areas in order to reduce the risk of fire or explosion on board vessels. The publication follows an increasing number of instances by the Coast Guard where there was a lack of knowledge regarding the installation,...
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50 dock fall hazard
How high are your loading docks? (1910.28(b)(1))
This citation is what we call a “gimme” as this can be found at just about every workplace that has loading docks.  We have written this up many times during our S&H audits, only to get some lovely looks and compliments from the facility personnel.  Many seem to think that if the dock is only 1-2″ over the 48″ height that this is not a violation of 29 CFR 1910.28(b)(1)(i). ...
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When 1926.64, OSHA's PSM standard for Construction would apply
First, let me state that this construction standard has never been cited.  This is based on my personal knowledge and the OSHA database; however, it is still in effect and could be cited.  Last year, OSHA revised their standards and they simply did away with the duplicate language in 1926.64 and said to follow the requirements in 29 CFR 1910.119.  But the bigger question to ask is when...
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More safety factors for flammable liquid safety systems - Inerting Systems
Many large scale processes that use Cat 1, 2, and 3 flammable liquids may also rely on a Nitrogen purge system to ensure the space within the process vessel is BELOW the Limiting Oxidizer Concentration (LOC) – sometimes called the Minimum Oxygen Concentration (MOC).  This safety system is based on the simple fact that if we maintain the level of oxidizer, usually the oxygen in the air but...
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Don't trust your SDS when working with your flammable liquids - NFPA suggest some safety factors be applied!
Many of us use Safety Data Sheets (SDS) on a regular basis and most of us have come to the realization that these documents fall far short of providing us the safety information we really need.  For example, when working with flammable liquids do you trust the SDS data to provide an accurate Flash Point for the material?  Because of the inherent errors in standard flash point measurements…...
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What is the proper resistance to ground for controlling static in flammable liquids transfers?
Bonding and grounding is a critical safety function when transferring flammable liquids.  But for the ground to function properly, how good must it be or in technical terms, how much resistance to ground is acceptable in the design of the safety system? … HomeRead More »
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2020 UPDATE on EPA's Initiative to Improve Safety of Ammonia Refrigeration Facilities in New England
Although anhydrous ammonia is an effective refrigerant, it is also a toxic chemical that can injure or kill people when accidentally released. The death of a worker at a Seafood plant in South Boston in 2016 is the most tragic example recently here in New England.  In 2018, the U.S. Environmental Protection Agency (EPA) launched a pilot initiative to improve compliance with the General Duty...
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When must a facility with an RMP covered process 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. But do all facilities subject to the risk management...
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EPA RMP citations @ agricultural chemical manufacturing facility (Cl2 release w/ 2 injuries & $31K)
Respondent owns and operates an agricultural chemical manufacturing facility. On November 2, 2017, Respondent had an accidental release of chlorine at the Facility. Respondent determined the amount of chlorine released to be 0.014 pounds and reported that the release occurred when hooking up a rail car containing chlorine in which an unloading valve was inadvertently opened when Respondent’s employees...
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