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EPA RMP citations @ chemical manufacturing and distribution facility (Anhydrous and Aqua Ammonia & $79K)
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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PRDs and their inspection and overhaul frequencies (API 576)
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. … HomeRead More »
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Why can't we use the PRESSURE CHANGE TEST in ASME Section V for leak testing B31.3 piping?
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: … HomeRead More »
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Where does it require I have an Oxygen Monitor when I use liquid Nitrogen?
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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Two Kansas Companies Fined $1 Million Each In Atchison Chlorine Gas Case
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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EPA RMP citations @ Refinery (Flammables & $?????)
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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Hand Sanitizer ALert VA OSHA
VA-OSHA Hazard Alert regarding hand sanitizer with 80% Alcohol
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 PSM citations @ chemical plant (Butadiene & $514K)
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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Determining frequency of emergency coordination activities (changes to response capabilities)
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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Face Coverings, flame-retardant/resistant clothing (FRC) and hazardous locations
UPDATED 6/4/2020 with an FR face-covering item. (NOT an endorsement!) Westex UltraSoft® FR Face Mask 7oz. Westex UltraSoft® 88% Cotton / 12% High Tenacity Nylon Sizes: Regular Colors: Orange (OR) Style: FR9805 Source: https://rascofr.com/product-category/face-covering/ Last week the good folks are DuPont opened a can of proverbial worms that about a dozen of us have been hotly debating behind the...
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Should we regress back to the basics?
Occupational safety used to be so simple and I believe we were better off then than where we are now.  When I started in the chemical industry in 1993, safety was a condition of employment.  What does that mean… you don’t follow the safety procedures and practices you will not be employed at the facility!  With OSHA’s PSM standard came a very formal “employee...
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Hand Sanitizer Did this
Have you seen this picture and story? (Hand Sanitizer car fire)
Have you seen this yet?  If not, you most likely will either via your social media activity or by e-mail.  This week this picture and various stories about what happened have gone “viral” after a Wisconsin Fire District posted it on their FB Account as an attempt to educate their followers.  The “shares” are over 6K as of this morning and it is now being circulated...
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