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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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Is combustible food dust subject to reporting under EPCRA Sections 311 and 312?
The definition of a “hazardous chemica” l under OSHA HCS includes “combustible dusts”. So, if the facility accumulates 10,000 lbs of dusts at any one time, it is reportable under Sections 311 and 312.  Facilities may want to consult FDA regulations to determine if certain food dusts would be covered under their regulations as food or food additive. If FDA regulates...
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NFPA 704 clear label
Does color coding on your NFPA 704 Diamond matter?
In the past several years the use of NFPA’s 704 “Diamond” as a means for secondary labeling has seen much scrutiny; however, even OSHA has stated that this label can be used as an in-house secondary label under the GHS labeling requirements. (SAFTENG members can see my earlier articles on this topic in the OSHA Compliance Section). But the use of the “Diamond” comes with...
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What should be included in our emergency pre-planning?
For those of us in the process safety arena, we hear about “pre-planning” almost daily (or maybe we should hear it that often!).  But when we actually start looking into what “preplanning” looks like, most facilities are lost at what they should be doing.  Once again, I turn to the International Fire Code (IFC) to establish a baseline of activities that should be done...
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Screen Shot 2018 08 18 at 10.30.08 PM
The Ventilation Design Basis begins with our intakes
All too often, when we ask for the “ventilation design basis” (1910.119(d)(3)(i)(E)) we are given some calculations from a 3rd party engineering group.  These calculations demonstrate the fan sizing for the necessary air exchanges and flows; however, what these calculations do NOT provide us is the full design basis for the ventilation system.  For me, the “design basis”...
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grinding over LPG exchange
2018 Photo of the Week #33 (Hot Work and Propane Exchange Cabinet)
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EPA RMP and EPCRA citations @ food facility (NH3 & $225K w/ 770 pound release)
Respondent is food facility that produces frozen French fries and other potato products.  It operates two (2) ammonia-based refrigeration systems at its facility.  Both E1 and E2 contain refrigeration systems which use anhydrous ammonia as a coolant.  On March 17, 2010, Respondent filed a program 3 RMP for the Facility (the “2010 RMP”), and updated it on September 20, 2013...
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2018 Video of the Week #33 (The power of a vacuum - Part II)
 
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United States Court of Appeals vacates the RMP Amendments Delay Rule
The United States Court of Appeals, FOR THE DISTRICT OF COLUMBIA CIRCUIT has reversed EPA’s delay of the RMP Amendments.  In its decision the courts states: … HomeRead More »
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Settling the Fit Test debate on when a QLFT vs. QNFT is required
This should not be new to many of you who have been reading my materials for years, but we continue to see Emergency Responders who are by default “entering IDLH atmospheres” who have been fit tested using a Qualitative Method.  In order to set the record straight, this is not a Haywood thing or a SAFTENG thing, this is an OSHA bare minimum thing… … HomeRead More »...
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2018 Video of the Week #32 (The power of a vacuum)
Occurred 5/8/18 at 7:30pm at a Paper Mill in MI. No injuries (besides truck drivers bruised ego and employment status). Mill Yard Worker asked driver 6 times if his vent valve was open. It wasn’t.
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Hot Work on Waste Water Tank Fatality
At 12:30 p.m. on September 27, 2017, Employee #1 was welding on the exterior wall of a wastewater storage tank. The tank became over-pressurized, causing an explosion. Employee #1 fell to the concrete floor below and was killed. … HomeRead More »
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2018 Photo of the Week #32 (Outrigger insanity... I'm sure their empty)
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