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In 2019, OSHA published a respiratory protection guide for Roofing Contractors, but since I do not work in the construction field I did not pay much attention to it. But today I found some never published guidance from OSHA regarding how an employer can establish a “change-out schedule”. I may have missed this in all the other OSHA/NIOSH documents regarding respirators or my...
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I really don’t understand the mindset of these companies… they have a horrible accident, and rather than recognize something failed and needs to be fixed, they hire lawyers to fight all the OSHA citations rather than competent/qualified safety professionals to fix it all. These citations were like “taking candy from a baby” because the company managed respiratory protection...
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OSHA cited a grain, lumber, and supply company for grain-handling safety violations after corn engulfed an employee clearing clumps in a grain storage bin. First responders were able to rescue the worker. The company faces $69,010 in penalties. OSHA cited the company for two willful and four serious violations for exposing employees to engulfment hazards while walking/working on the grain to make it...
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Respondent owns and operates the chemical manufacturing and distribution facility. Anhydrous ammonia is a “regulated substance” pursuant to 40 C.F.R. § 68.3 with a threshold quantity, as listed in 40 C.F.R. § 68.130, of 10,000 pounds. Ammonia in the concentration of greater than 20% is a “regulated substance” pursuant to 40 C.F.R. § 68.3 with a threshold quantity for ammonia...
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A baseline of every 5 years is recommended; however, there are some critical exceptions that would require more frequent inspections. And if the process is CLEAN (e.g., Non-Fouling), we could go 10 years WHEN the manufacturer permits. Here is a breakdown of these frequencies, using API 576 and NB Part 4.
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ASME B31.3 does not permit the use of an “ASME Section V Pressure Change Test” as a substitute for the mandatory leak testing requirements (hydrostatic, pneumatic, or initial service leak test) defined in Chapter VI of the B31.3 Code.
Why It Cannot Be Used as a Substitute:
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OSHA may use its General Duty Clause (GDC) to require employers to install oxygen monitors in areas where inert cryogenics are stored or used. But I like to use codes/standards (e.g., RAGAGEPs) to guide my safety engineering for these hazardous processes, even though PSM/RMP does not cover them. To do this, I turn to the International Fire Code (IFC) applicable to my state. Here is the language...
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Sorry, I have not seen any actual citations or details of how this incident occurred, but I will update if I get anything.
A chemical supplier and an Ingredients’ facility have been fined $1 million each for violating the federal Clean Air Act when a cloud of toxic chlorine gas was released over Atchison, Kan., in 2016. Both companies have paid the fines. U.S. District Court Judge Daniel...
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I am not sure how much of the $4 million was for RMP, as there were other issues in this Consent Decree and I have only pulled out the RMP issues.
On or about September 4, 2017, heater tube 23 ruptured in the CRU2/HTU2 charge heater process due to creep, a molecular failure mechanism that causes metal deformation as a result of stress from high temperatures. The rupture of heater tube 23 caused the...
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Last week, VA-OSHA posted this Hazard Alert regarding hand sanitizers with 80% alcohol. Now I am not aware of any studies that differentiate the hazards of 80% versions from 70% and 65%% versions or of any incidents where static ignited the sanitizer when the user touched a grounded surface. But we do know that Alcohols have Minimum Ignition Energies (MIE) less than 1 millijoule (mJ) and...
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OSHA has cited a texas chemical company for exposing employees to workplace safety and health hazards after a fire and explosion at the plant in November 2019. The company faces $514,692 in fines. OSHA opened an investigation after vapor formed at the base of a butadiene finishing tower ignited and caused several explosions and fires. OSHA cited the facility for three willful violations for failing...
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Today, the EPA’s RMP Info Center published the following guidance on the REVISED emergency coordination activities in the RMP Rule. The Risk Management Program regulations require owners and operators of stationary sources to coordinate their response needs ANNUALLY, or more frequently if necessary, with local emergency planning and response organizations (40 CFR §68.93(a)).
Are stationary...
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