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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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Pipe Labeling and ASME A13.1 (EPA RMP & $2,700 and $89K abatement costs)
For those of you that follow my ramblings have heard me rant on about ASME A13.1 and how pipe labeling begins LONG BEFORE a process becomes a PSM/RMP covered process.  ALL Hazardous Materials piping has to be labeled!  And yes I am well aware of OSHA’s position on pipe labeling and their Globally Harmonized System for Hazardous Communications… Container means any bag, barrel,...
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Table 1. Summary of IST Measures Implemented or Scheduled by Sector
Inherently Safer Technology Reviews (NJ TCPA)
On March 25, 2008, the State of New Jersey adopted rules requiring facilities regulated under the Toxic Catastrophe Prevention Act (TCPA) Program, which is PSM/RMP to those of us outside of the state of New Jersey, to perform Inherently Safer Technology (IST) reviews. Both OSHA and Federal EPA have tried to incorporate the IST model into their PSM and RMP standards with no luck.  In the process...
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SILO: Short Documentary
SILO: Short Documentary from Blood Orange Pictures on Vimeo.
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OSHA issues Regional Memo on Enforcement Guidance for Use of Respiratory Protection Equipment Certified under Standards of Other Countries or Jurisdictions During the Coronavirus Disease 2019 (COVID-19) Pandemic
MEMORANDUM FOR: REGIONAL ADMINISTRATORS, STATE PLAN DESIGNEES THROUGH: AMANDA EDENS, Deputy Assistant Secretary FROM: PATRICK J. KAPUST, Acting Director Directorate of Enforcement Programs SUBJECT: Enforcement Guidance for Use of Respiratory Protection Equipment Certified under Standards of Other Countries or Jurisdictions During the Coronavirus Disease 2019 (COVID-19) Pandemic   This memorandum...
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OSHA PRCS citations @ University (Steam Vault & $235K)
OSHA cited three employers – a University, a Mechanical contractor and an HVAC contractor – for exposing workers to permit-required confined space hazards associated with underground steam vaults. Proposed penalties for the three companies total $235,962.  OSHA received an employer-reported referral from the mechanical contractor after an employee suffered burns from a release of steam while working...
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And you wonder why OSHA writes these standards (Exit height and Working Order)
In this one, we get a 2-for-1 special!!!! First, the egress path height… 1910.36(g)(1) The ceiling of an exit route must be at least seven feet six inches (2.3 m) high. Any projection from the ceiling must not reach a point less than six feet eight inches (2.0 m) from the floor. and then the emergency fire door MUST be able to close! 1910.37(a)(4) Safeguards designed to protect employees during...
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Free EHS Web Training (Listing of Resources)
From my friend Bill Geddings… In an effort to help EHS professionals who are missing conferences, local professional development meetings and other training opportunities that will allow us all to maintain certifications and our competencies please share known online learning opportunities.  These can be environmental, occupational health, safety, leadership, emergency response, etc. I will...
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TABLE H 15 INDOOR PORTABLE TANK STORAGE
When a business converts to handling flammable liquids for the pandemic response (Part 2 - Indoor Storage)
Earlier this week I explained the OSHA requirements for storing Flammable Liquids “outside”, using Ethanol as my example since so many businesses have been converted over to making hand sanitizers, many of which have never managed such a large inventory of flammable liquids.  Part 2 is to cover those businesses who wish to store their Ethanol Inventory inside a building, but NOT inside...
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flammable liquids in totes
Outdoor Storage of Flammable Liquids in containers and portable tanks
The humanity and compassion that many ordinary businesses are showing during this pandemic are heartwarming and patriotic.  But it is also very concerning and quite frankly dangerous to see some of the images from their public announcements of their efforts.  As a profession, we need to step up and help these businesses manage their hazardous materials properly so that they can aid in this...
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Snowed egress
Don't forget "building construction" in your PSSR
Although the idea of this article originated from a PSSR debacle on a new process construction project, the information will apply to ALL building construction and so I have put this in the OSHA Compliance Category rather than the Chemical Process Safety category.  Late last year we were finishing up a longterm project with a client who was building a new process that would eventually be a PSM/RMP...
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RCE Logo Copy 676x82
Compliance in a time of COVID-19 Pandemic
Brian Chapin, Compliance Services Manager NOTE: This article is by my good friend and colleague Brian Chapin @ RC&E in Forth Worth, TX.  In full disclosure, RC&E has been a corporate member for several years.  Brian was gracious in allowing me to post his work directly at SAFTENG as some of you were having issues with the RCE Chill page.  But for those of you who can access his...
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NEVER use the HHC/EHS as your pressure/leak testing media
On June 29, 2005, an operator was involved in the following maintenance activities in the Chloropyridines Complex at the employer’s chemical manufacturing facility. He was returning a reactor vessel to service and WAS ATTEMPTING TO DO A PRESSURE AND LEAK TEST USING CHLORINE GAS. The pipeline was supposed to be pressure tested with nitrogen gas during the previous shift. During the test, the employee...
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