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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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EPA RMP citations @ refrigerated warehouse and storage facilities (NH3 & $53K w/ $112K SEP)
Respondent is a business that owns and operates two (2) refrigerated warehouse and storage facilities located in Nebraska and Minnesota. The Nebraska facility is located in EPA Region 7 and the Minnesota facility is located in EPA Region 5. Information gathered during the EPA inspection revealed that Respondent had greater than 10,000 pounds of anhydrous ammonia in a process at its Nebraska facility....
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CSB's Accidental Release Reporting
Here is an initial look at the rule, signed by the CSB Interim Executive today. The final rule requires an owner or operator of a stationary source to submit an accidental release report to the CSB. The rule describes when to file a report of an accidental release and the required content of such a report. The purpose of the rule is to ensure that the CSB receives rapid, accurate reports of any accidental...
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Permit-Required Confined Space Program (w/ Construction requirements)
Attached is the written program for General Industry facilities which incorporate OSHA’s newer Confined Spaces in Construction requirements.  It is my recommendation that we UPDATE our written program that was based on the older 1910.146 standard to include all the improvements in 1926.1201 – .1213.  We should also understand that even though our facility may fall within OSHA...
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No Procedure for Requesting RMP Five-Year Review Extension
The Risk Management Program (RMP) regulations require the owner or operator of a stationary source to revise and update the source’s RMP at least once every five years from the date of its initial submission or most recent full update (§68.190(b)).  Is there a procedure for obtaining an extension to complete the five-year review?  … HomeRead More »
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Types of Information Relevant for Response Planning
The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency planning and response organizations...
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Time Frame to Submit RMP Emergency Contact Information Changes
How much time does the owner or operator of a stationary source have to submit a correction to a Risk Management Plan when the emergency contact information changes? The Risk Management Plan (RMP) regulations require an owner or operator of a stationary source to correct their RMP within one month (i.e., 30 days) of any change in the emergency contact information required under 40 CFR 68.160(b)(6)...
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Energy Isolation in a chemical process is a "complex LOTO"
Under most circumstances, where servicing or maintenance is to be conducted during only one shift by a small number of persons, the installation of each individual’s LOTO device on each energy isolation device would not be a burdensome procedure. However, when complex equipment is being serviced or maintained, when there are many sources of energy, and/or when servicing/maintenance work extends...
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What does it mean when we say "operations own safety"?
The first element is whether strategic plans and action plans integrate safety into all aspects of an organization’s activities. Are there measurable short, medium, and long-term safety objectives in these plans, and is there regular progress monitoring in implementing the plans? Monitoring progress by the senior management team is vital to good safety leadership. Regular plans should be reviewed to...
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There is no "I" in LOTO, but there should be!
Anyone who has played sports or even just attended a team sporting event has heard or seen the famous saying: There is no “I” in Team! In our world of Lockout/Tagout (LOTO), nothing could be farther from the truth!  There is not an act in occupational safety and health that is more self-serving and selfish than LOTO.  Even in Group LOTO situations, LOTO is ALL about EACH WORKER...
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Ammonia compressed gas cylinder storage
Can cylinders of Anhydrous Ammonia (NH3) be stored with oxygen cylinders?  This is not meant to be a trick question, but it is a question I find to be confusing for employees who place cylinders into storage.  So what is your answer: Can cylinders of Anhydrous Ammonia (NH3) be stored with oxygen cylinders? … HomeRead More »
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EPA RMP citations @ seafood processing facility (NH3 & $61K)
Respondent operates a seafood processing facility where anhydrous ammonia was present in a process above the 10,000 pounds TQ. Respondent has one program 3 process, an ammonia refrigeration process consisting of a brine chiller system, seven plate freezers, one blast freezer and one ice house with three ice machines. An RMP was submitted for the Facility on February 14, 2014, and March 27, 2019. ...
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Key Safety Measures for Ammonia Refrigeration Processes (EPA & IIAR)
The following is a list of key safety measures developed by EPA in coordination with the International Institute of Ammonia Refrigeration (IIAR). They are measures that EPA and IIAR agree are required elements for ammonia refrigeration facilities (regardless of an ammonia refrigeration system’s age or size) for the system to meet the requirements of 40 C.F.R. Part 68 or the General Duty Clause...
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