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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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For years, PHA’s seemed to always list vessel “relief systems” as a “safeguard” for ALL the HIGH-PRESSURE scenarios involving the vessel. In this article I want to challenge this practice; but to be up front, if you were to look at all my PHA’s I was guilty as sin for doing this very thing. But as I do more and more PHA’s on all kinds of interesting...
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As I have stated already this week, I am a HAZOP kind of guy. I have used just about every methodology under the sun over the past 25+ years, and I have come to a personal conclusion that in almost every occasion, a HAZOP would have been the best methodology to utilize for a correct Process Hazard Analysis. My next favorite tool is to use a Failure-Modes-Effect-Analysis (FMEA) on specific...
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Earlier this week I posted about how a PHA should document its consideration of the engineering controls and administrative controls failing. And I said back in the 2013 posting; this little requirement is intended to make facilities dig past a single layer of protection and maybe even identify a lack of engineering and/or administrative controls for a process deviation. But let’s be clear, a...
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This is a follow-up to a previously posted case. An electrical contractor at a steel mill was in a danger zone when the mill technician began locking out the equipment. The LOTO procedure required some counterweights to be lowered to the ground (i.e., ZES). When the mill technician released the counterweight, an apprentice with the electrical contractor was standing underneath it...
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With all the recent attention being paid to EPA and it’s Risk Management Plan amendments and many of those amendments being rescinded by the new administration, I thought it would be a good time to remind those in the PSM/RMP world, that OSHA has their own wish list (my phrase – not theirs) and some of their proposed changes could have MUCH larger impacts on businesses than any of...
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In the RMP Amendments rule, EPA added three major provisions to the accident prevention program of Subparts C (for Program 2 processes)and D (for Program 3 processes). These included:
A requirement in § 68.60 and § 68.81 for all facilities with Program 2 or 3 processes to conduct a root cause analysis using a recognized method as part of an incident investigation of a catastrophic release...
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