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This case is being posted, even though the citation was under $10,000 because it is a GDC case and involved improper storage of materials that would react to create an extremely hazardous substance. EPA used both NFPA 30, 2015 and the IFC, 2015; as well as NFPA 704 in their assessment. The respondent has owned and operated the chemical manufacturing facility since 2001. Respondent...
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This is a classic. Details matter, contrary to what many want to claim about safety plans, programs, practices, and operating and maintenance procedures. The fact is, there MUST be a balance between details and length and complexity. Some jobs will need a 10-page procedure, and some will need a half-page. The idea that shorter is always better is a falsehood driven by laziness and...
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Over the years, I have encountered some great learning opportunities, many occurring during my VPP assessments. In one such evaluation in Alabama, the CSHO pointed out that our PRCS Labels were on the actual coverings over the entry portals (e.g., manways). As he explained, in that set-up, OSHA would not require the space to be labeled; however, as soon as the manway comes off the vessel,...
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In OSHA’s 2018 Permit-Required Confined Spaces; Extension of the Office of Management and Budget’s (OMB) Approval of Information Collection (Paperwork) Requirements, they noted some fascinating numbers as they relate to PRCS’s in the USA…
number of establishments with permit spaces = 210,281number of entrants entering these spaces = 1,471,634
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Respondent owned and operated a Natural Gas Processing facility, which produces, processes, stores, or handles more than 10,000 pounds of a flammable mixture, including pentane, isobutate, isopentane, butane, propane, and ethane in the form of natural gas, natmal gas liquids, condensate, and/or crude oil. Pentane, isobutate, isopentane, butane, propane, and ethane are identified at 40 C.F.R....
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The CSB faces two management challenges that, if not addressed, may seriously impede the agency’s ability to achieve its mission efficiently and effectively.
Based on our continuous audit work, the EPA OIG has identified two management challenges for the CSB that were not in the fiscal year 2017 report:
the lack of authority that the position of CSB Chairperson has over board members,...
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UPDATED 2/16/2021 with OSHA Case File
A couple of KEY POINTS in this EMA’s report out to the County Supervisors:
Two weeks before this incident the County had conducted a drill at another NH3 facility that involved a rooftop NH3 leak (PREPAREDNESS)
The release came from a 14″ diameter suction line on the roof of the facility. The pipe failure is said to have been caused by a “stress...
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Here is an unfortunate incident that draws our attention to operating elevating equipment inside refrigerated spaces. This incident also demonstrates the increased hazards to workers working within these elevated devices, as their means of egress, should there be a chemical release, is GREATLY compromised. Lastly, we should NOT lose sight of the fact that this young man was NOT working ON the...
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This week Facebook provided the usual ton of garbage available in the human race! This week a friend shared a posting about how Americans are calling Uber instead of an ambulance; not because Uber is faster, but because ambulance rides are so much more expensive. This was what appeared to be a legitimate hit piece (I say it was done as a publicity stunt). But here’s the thing…...
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One of the things I find extremely unfair with EPA citations is that they are based on “revenue” of the business, as well as other factors. I like it when it is applied to a “for-profit” business, but it is disproportionately UNFAIR when it is applied to a public utility like a water treatment plant. Case in point, this WTP was NOT practicing process safety and even...
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EPA RMP Citations @ fruit processing plant and controlled temperature storage warehouse (NH3 & $53K)
The Company owns and operates a fruit processing plant and controlled temperature storage warehouse, near a mixed business-residential area approximately one half mile northeast of a college campus and approximately one-half mile east of a downtown area. The facility uses anhydrous ammonia in a “closed-loop” refrigeration system. According to the Respondent, as of February 2, 2016,...
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