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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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This is why ASME B31 series requires us to have written procedures for pressure and leak testing the piping
On March 13, 2007, Employee #1, a subcontractor, performed maintenance on commercial foodservice equipment. He was in the kitchen area of a single-story restaurant, attempting to locate the source of a refrigerant leak in an ice cream storage dipping cabinet. Employee #1 connected a Nitrogen cylinder to the dipping cabinet’s refrigeration system via a hose WITHOUT using a pressure reducing device,...
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Leak testing gone bad (Bubble test on NH3 pipe/valve weld)
A refrigeration system was being installed in a new wing of an ice cream plant in 1984.  A leak test was being performed by employee #1 on a “low-pressure tank” which was filled with a mixture of ammonia and air under a pressure of 150 psi. As he squirted a soap bubble solution onto a butterfly valve, the valve suddenly popped completely open. The force of the outrushing NH3/Air gases...
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Line Break gone BAD (replacing a defective NH3 pressure gauge)
At 11:30 a.m. on September 04, 2018, a group of employees was working on a beef processing station. Employee #1 was REPLACING A DEFECTIVE AMMONIA PRESSURE GAUGE FOR A HOT-GAS AMMONIA LINE when he broke off the gauge and associated valve, releasing ammonia into the area and cut/fab floor below. The plant was evacuated and 14 employees were treated and released for ammonia exposure and one employee was...
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Hand sanitizers that have 60% Alcohol are Category 3 FLAMMABLE LIQUIDS (Part II)
My March 16th article about the hand sanitizers being a CAT 3 Flammable Liquid caused quite the ruckus.  Many did not want to accept the fact until they went and found out on their own that these alcohol-based hand sanitizers are indeed flammable liquids.  And once they came to this realization the questions started to pour in.  The International Fire Code (I am using the 2018 edition)...
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CO2 Cylinder Rupture
A gas cylinder was found in the parking lot of an event facility by staff arriving at work. The cylinder had launched from the concessions area the night before. … HomeRead More »
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The mortality rate is really low for COVID-19 so this is overkill (all pun intended)...
This is the new mantra being spewed by the none believers now that the infection rate has destroyed their earlier argument that the virus is not a problem in the USA.  Here is the full story as to why our mortality rate is trending so low right now… EARLY in the spread, relatively few need medical care at this time.  What happens with these pandemics is the medical care is overrun because...
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EPA RMP citations @ LPG Railcar filling facility (LPG & $14K)
On July 12, 2017, authorized EPA representatives conducted a compliance inspection of the facility to determine its compliance with the Risk Management Program (“RMP”) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Act. Following the inspection, EPA requested certain documents and information and reviewed the provided information with support from outside specialists....
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