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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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Respondent owns a stationary source where anhydrous ammonia was present in a process above the 10,000 pound TQ from at least June 1, 2014. Therefore, Respondent was required to submit and have in place an RMP for the facility. Respondent submitted an RMP to EPA on April 9, 2015. Respondent has a Program 3 covered process. Here is what EPA found:
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I may have been quick to “pat myself on my back” last week with my post titled “It took two (2) years, but HFO-1234yf is now a NFPA Flammable “4”, as this morning I learned from another client dealing with this refrigerant that their manufacturer also updated their SDS and guess what… that manufacturer went from an NFPA Flammable “4” down to a Flammable...
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I have joked about this topic in other posts, as we have been battling the idea that our new refrigerant for vehicle air conditioners is a Category 1 Flammable Gas. This conversion from R-134a has been a bumpy one, but in jest, I share with you EPA’s “use conditions,” and for an agency that certainly played along with industry, they sure did have some requirements that sound...
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The US Chemical Safety Board’s (CSB) most recent Safety Bulletin: Key Lessons from the ExxonMobil Baton Rouge Refinery Isobutane Release and Fire was once again a great piece of work by the agency. But as with most incidents, other underlying issues may have contributed (or not) to the incident. In this bulletin, I could not help but notice a poor practice, as shown...
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The OSHRC sided with the company that used Appendix A from 1910.147 as their machine-specific LOTO procedure. They did so without any revisions to the content of the Appendix, and the OSHRC found this as an acceptable machine-specific LOTO procedure!
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This case involved an industrial laundry company which uses continuous batch washers (CBW) which were correctly defined as a Permit-Required Confined Space (PRCS). During an OSHA inspection, the Compliance Officer (CO) took issue with the facility’s rescue plan from a CBW. After reading this case, I too took issue with their rescue plan; however, since the secretary was unable to explain the...
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This OSHRC case involved laundry company who uses industrial sized washing machines which are correctly classified as a Permit-Required Confined Space (PRCS). OSHA inspected the facility, and the CSHO discovered that the calibration gas used to calibrate the direct reading meter that would be used for testing the atmosphere inside the continuous batch washers (CBW) has expired...
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I often review the OSHRC decisions to learn better the “legal” side of OSHA compliance and most of the time I find that the Review Commission is pretty much a straight shooter when it comes to applying OSHA standards. But there are times when I close my computer as if I just saw a ghost after reading some of their rationales! Sometimes it is OSHA’s fault for poorly explaining the...
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At this year’s NSC Congress OSHA announced their 2017 Top 10 Violations. They have not updated their Data Page yet, but here are their preliminary…
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Respondent is primarily engaged in the production of anhydrous ammonia, urea fertilizer, and urea ammonium nitrate, which includes two ammonia units (A1 and A2), a urea production unit, a UAN unit, and various ancillary units, including a carbon dioxide pipeline compressor station and a hydrogen recovery unit. Respondent produces, processes, stores, or handles more than 10,000 pounds of anhydrous ammonia...
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