In a mature Safety Process/SMS these four (4) elements play a critical role in delivering VALIDATED data to management so that the data can be analyzed and properly responded to in order to INTERVENE in the conditions/actions/attitudes BEFORE an event delivers undesired consequences. The late great Trevor Kletz said it best three decades ago in his first series of books, What Went Wrong? “In...

While anhydrous ammonia has many environmental and operational benefits, it is also an extremely hazardous substance that, if accidentally released, presents a significant health hazard because it is corrosive to the skin, eyes, and lungs. Ammonia is also flammable at certain concentrations in air. The Environmental Protection Agency (EPA) would like to work with facilities that have ammonia refrigeration...

Respondent is the owner and operator of a facility. Respondent operates a bulk liquid storage facility and offers a full range of heating, blending, and product services. Various products, such as vegetable oil, chemicals, and petroleum products, are received in tanks for storage and transferred out of the facility to customers. Some of the petroleum products may be considered flammable, so Respondent...

Today, OSHA posted its latest LOI.  This one was regarding railroad track employees and roadway maintenance groups and the need to provide sanitation facilities for these workers. Question: Do OSHA’s sanitation requirements apply to railroad track employees and roadway maintenance groups that are working along the tracks? Answer: Yes. Under section 4(b)(1) of the Occupational Safety and Health...

During a recent offshore inspection, a BSEE inspector observed operator personnel installing a 100-foot high-pressure hose, with a Maximum Working Pressure (MWP) of 5000 psi, to test pressure safety valves on pipeline pumps. The hose used was designed for hydraulic fluid and not suitable for high-pressure nitrogen; when nitrogen gas at 2500 psi was injected into the hydraulic hose, the hose blistered,...

The NY City Bridge got hot because the drive train that moves it overheated, NOT because “climate change” or ambient temperatures caused the bridge to “swell.” I am not a metallurgist, but I did stay at a Holiday Inn Express last week. If this bridge can not operate within its design tolerance because the ambient temps reached the upper 80’s, I will be damned if...

Lithium-ion battery manufacturing has garnered a lot of news lately, both good and bad news. Although these batteries are being manufactured in the name of being “environmentally friendly,” as is the case in many PSM/RMP-covered processes, the raw materials used in their manufacturing are anything but “friendly.”  The PSM process in this manufacturing process involves the...

We have discussed pressure and leak testing piping in our hazardous materials processes, specifically in our PSM/RMP-covered processes. The International Fuel Gas Code (IFGC) has some great specifics on how we test natural gas piping. Interestingly enough, the IFGC code defines “pressure test” as… (emphasis by me) An operation performed to verify the gas-tight integrity of gas...

On March 3, 2009, at approximately 1:29 p.m., Employees #1 and #2 were conducting a gas line pressure test on a 20-inch gas line. The test involved pressurizing the line to 100 psi and holding this pressure for one (1) hour. This test was conducted to determine whether the gas line being tested could be reused or needed to be replaced. During the test, the pipe failed under the pressure. …...

On May 18, 2023, at 7:45 p.m. an employee, 45, working for a paint and coating manufacturer was wearing a 3M half-face respirator while spray coating MacroPoxy 646 Fast Cure Epoxy on parts. The employee was spraying the last parts of the day when he began feeling chest pain. The employee used his inhaler twice but passed out. A coworker (supervisor) called an ambulance which took the employee to the...

Without question, the #1 question we receive regarding Hazardous Locations is… When do I need one?  With flammable liquids (e.g., FP<100F) it is easy to perform the evaluation.  But what if my flammable solution is a CAT 3 or 4 (i.e., Class IIIA or IIIB)?  As the title says, not all flammable solutions require us to establish a HAZLOC.  And a CAT 3 or 4 flammable liquid...

A tank cleaning company again chose to disregard federal safety standards that may have protected their employees from hazardous working conditions and prevented another employee from suffering a fatal injury. In December 2023, just two days before Christmas, the wife and son of an employee at the company grew concerned when he didn’t return after his shift. Later that day, he was found unresponsive. A...