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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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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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Owner / operator compliance audit timeline
Must an owner or operator conduct and document a compliance audit at the time of an update required under §68.190 if the update is made within three years of the original RMP submission? … HomeRead More »
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Process Safety Information... sweating the small stuff (Flange Bolts/Rods)
In the world of process safety, every little detail adds up; so as one of my favorite bosses always said… “sweat the small stuff”!  This became crystal clear during an incident investigation where a flanged connection was the point of release.  Most people look at a flanged connection as a simple means to connect to ends of pipe together, but oh it is so much more and thus...
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21762341
Designed with maintenance in mind, NOT! (Ammonia Refrigeration header detection)
Several years ago, we discussed this picture in terms of a Relief Design Basis, the NH3 vent header sensor placement in terms of NFPA 70 HAZLOC, and the risk of doing maintenance/calibration on the sensor when the process is live.  As usual, I got some nice feedback, and the usual haters chimed in that I was off my rocker once again, stating their usual mantra… “that is industry practice...
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