I have this debate several times a year and always go to the “note” in 1910.146 related to the definition of “atmospheric hazards”.  And that is never enough to convince people that 1910.146 deals ONLY with ACUTE responses to atmospheric hazards – NOT chronic responses.  Now let’s be clear that chronic hazard MUST be addressed/managed, but it falls outside...

Respondent was the “owner or operator” of the Facility. The Facility’s refrigeration system used approximately 5,913 pounds of anhydrous ammonia. Accordingly, at the time of the violations alleged herein, Respondent operated a stationary source that handled and stored anhydrous ammonia, listed at 40 C.F.R. § 68.130, and thus was subject to the General Duty Clause found in section 112(r)(1) of the CAA....

Respondent is the owner and operator of a facility where EPA inspected from May 17 to May 19, 2022, to determine Respondent’s compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68 (“the Inspection”).  The Respondent’s facility is a metal alkyl manufacturing facility.  The facility produces a variety of highly reactive metal alkyls including aluminum, magnesium,...

Catastrophe requires multiple failures – single-point failures are not enough The array of defenses works. System operations are generally successful. Overt catastrophic failure occurs when small, apparently innocuous failures join to create opportunity for a systemic accident. Each of these small failures is necessary to cause catastrophe but only the combination is sufficient to permit failure. Put...

An ammonia leak occurred inside the machinery room of a public athletic club with indoor ice facilities. The leak happened during the decommissioning work of an ammonia refrigeration condenser by a licensed refrigeration contractor, which resulted in the facility enacting its Ammonia Release Emergency Protocol. The incident was likely caused by the contractor not properly purging and vacuuming the...

One of the top questions newcomers to process safety ask is, “Why do I have to have a written procedure to remove and install new relief valves?”From the EPSC Learning Sheet October 2024What Happened:The bonnet vent in a Balanced Bellows Pressure Safety Valve (BB-PSV) was found in service, but still fitted with a shipping plug. Internal leakage past the bellows would give back pressure,...

Respondent owns or operates the AMPI production facility that uses anhydrous ammonia in its refrigeration processes. From December 20, 2021, to May 17, 2022, EPA conducted an offsite compliance monitoring investigation of the Facility. During that investigation, the EPA representatives identified alleged violations of section 112(r)(1) of the CAA and section 312 of the EPCRA. EPA’S ALLEGED VIOLATIONS...

Respondent is the owner and operator of a facility that has more than 10,000 pounds of anhydrous ammonia and Hydrogen in processes. Information gathered during the EPA inspection revealed that Respondent uses anhydrous ammonia in the production of food ingredients and produces and stores hydrogen, and therefore, is engaged in a process at its facility. Allegations of Violation COUNT 1 The EPA inspection...

According to reports, thirteen (13) explosions, three (3) of which involved fatalities, occurred over the past ten (10) years, leading to the grounding of hundreds of refrigerated containers worldwide. The causes of the explosions were investigated and thought to have been caused by contaminated or incorrect refrigerant being added to the refrigeration system while it was in service in Vietnam. A shipper...

It has been 1-month since the tragic death of Greene County Fire Rescue Battalion Chief Chris Eddy in GA while working a semi-truck fire on the side of the roadway. We still have not received any formal information on this event, but there has been some erroneous reporting.  Out of respect for Mr. Eddy, I promised to wait for official word on this accident’s cause and contributing factors....

It is a common question… why does OSHA define entry as… Entry means the action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space. This work took place on a ship in a flammable...