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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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Back in 2015 I wrote about changing the “service” of a pressure vessel and all that should be considered in this change. Late last year my team and I ran across a very common error in “changing the service”, albeit the change was an actual change of location. Here’s what happened…
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The transfer of Class IA liquids from polyethylene drums and containers may be safety accomplished and is deemed to comply with the intent of the standards at 29 CFR 1910.106(e)(6)(ii) and (h)(7)(i)(b) when:
A polyethylene drum is equipped with an approved metallic suction pump and draw tube for taking liquid through the top of the drum and the pump is electrically grounded, or
The drum or container...
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OSHA does not have any provisions that require the emergency relief devices on PORTABLE TANKS to discharge to the outside of buildings. However, if portable tanks are part of a PSM-covered process, at a minimum, the employer would be required to IDENTIFY, EVALUATE, AND CONTROL [§1910.119(e)(1)] the hazard of discharging flammable and combustible materials through an emergency relief device into...
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OSHA bases their position on which section of 1910.106 would be applicable; if the plant is an industrial (covered under 1910.106 (e)) or a processing plant (covered under 1910.106(h)). If the operation is an incidental activity covered by §1910.106(e)(2), paragraph §1910.106(e)(2)(iv)(d) allows transfer of flammable or combustible liquids into vessels, containers, and portable tanks...
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OSHA’s says No; 1910.106(e)(2)(iii) does NOT require the exclusive use of fresh air for ventilation purposes. OSHA states that 1910.106(e)(2)(iii) is a performance requirement and does NOT explicitly require the introduction of fresh air to meet the performance requirements of the OSHA standard. OSHA, under §1910.106(e)(2)(iii), expects employers to provide adequate ventilation to...
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We are no longer surprised when we come across a “process” which is not a PSM-covered process because the facility has managed the quantity of their HHC below OSHA’s threshold. However, from a risk perspective, having 9,975 pounds of an HHC versus having 10,000 pounds does not lessen our process or personnel risks, but that is another discussion for a rainy day. Recently we came across...
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Respondent produces meat and protein products for sale by third-party customers. As part of this process, Respondent uses anhydrous ammonia in a chill tank to prepare and preserve the products. Ammonia is a regulated substance listed in Table 1 to 40 CFR § 68.130. On the evening of January 15, 2016, after the Facility had closed its operations, a worker employed by a sanitizing equipment was sanitizing...
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One of the top questions we get when working with clients whose primary business is storing, handling, and processing flammable liquids is…
How many flammable storage cabinets can we have in the same area?
This answer used to be easy, but these days – not so much. Back in the day, NFPA 30 (2000 Edition) stated the answer clearly…
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In 2011 someone wrote to OSHA and specifically asked for clarification on the use of the words “or” and “nor” in the paragraph Design, Construction, and Capacity of Storage Cabinets-Maximum Capacity, 1910.106(d)(3)(i), which states:
“Not more than 60 gallons of Class I or Class II liquids, nor more than 120 gallons of Class III liquids may be stored in a storage cabinet.”
This...
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In my Process Safety, HAZMAT, and Emergency Response course, I always walk the students through an exercise to demonstrate just how dangerous chemicals such as Cl2 and NH3 are. So many have come to believe that these chemicals are hazardous only when we exceed the OSHA/EPA Thresholds for PSM/RMP.
In a 40 ft × 40 ft space with an 8ft ceiling, we need only 111.5 mL (0.0303798 gallons) of liquid NH3...
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