I love the CSB’s work, but this study could have been said in really simple terms… State Fire Code(s)!  I have written dozens of articles explaining the specific requirements of the International Fire Code (IFC), from which most of the 50 states have adopted some “revised” version.  Chapter 50 of the IFC (and those states that adopt it) has very specific requirements...

Many thanks to my friend in safety down under, Mr. Peter Hunt, Director and Principal Consultant, Whamcorp Pty Ltd On 25 March 1991, a contractor died after an ammonia tank he was upgrading exploded at the ICI plant. BACKGROUND … HomeRead More »

At its facility, Respondent converts paper products into finished products such as rolls of toilet paper and paper towels. The paper products are run through machinery operated by Respondent’s employees. One of these machines is the R74 Line Rewinder (Rewinder) machine. The Rewinder transforms a 10-foot by 10-foot giant roll of toilet paper into the smaller more commonly sized roll of toilet paper....

The Hydrant and PIV must be protected, so we installed two (2) “lazy bollards.” The post are correct, their installation is NOT to code. Had they been installed in the parking lot with a 15” diameter footing and at a height of 4’ AND 4’ away from the PIV, then all would be OK. But they were not, so one day, the bollard failed to protect the asset, causing a major leak and a failure of fire...

In 2012, I discussed the use of sulfur sticks and asked a question: Sulfur sticks and ammonia leaks… are you in compliance when using these leak detection devices? In 2014, IIAR updated its edition of ANSI/IIAR 2 – Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems, which PROHIBITS their use when charging is being performed and when oil or ammonia is being removed from the...

In almost every PHA I have done since 2000, we find safety critical valves or instrumentation with a built-in bypass around them. I understand the need for a bypass WHEN IT IS FOR MAINTENANCE of the device, but in no sane world do we put a bypass around a safety-critical device so that the process can run if that safety device fails in the CLOSED position. NO WAY IN H_LL will I accept that. When we...

The operators of a global ink and coatings manufacturing company could have prevented an employee from suffering burn injuries from a flash fire that erupted in an industrial mixing vessel containing flammable liquids and vapors by following federal regulations for handling of highly hazardous chemicals. An OSHA investigation determined a flash fire sparked in the mixing vessel as the employee manually...

OSHA’s Construction Standard for PRCSs specifies several information collection requirements. The following sections describe who uses the information collected under each requirement and how they use it. Employers and employees would use these information collection requirements to identify a confined space at a construction worksite. The purpose of the information would permit employers and...

How many code/RAGAGEP violations can you identify? Tip: Code(s) and RAGAGEPs require equipment to be protected against contact with mobile equipment when that contact could lead to an LOPC event involving a hazardous material. Answer(s) below: … HomeRead More »

Imagine trying to build a house today without the proper tools, such as a hammer/nail gun, handsaw/power saw, and tape measure. These are obviously critical to the task being done WELL and EFFICENTLY. Sure, we could build a house without them, but would it be one we would buy and put our family in for 30-40 years? The same scenario applies to building a safety process/SMS! We have tools that have been...

In a mature Safety Process/SMS these four (4) elements play a critical role in delivering VALIDATED data to management so that the data can be analyzed and properly responded to in order to INTERVENE in the conditions/actions/attitudes BEFORE an event delivers undesired consequences. The late great Trevor Kletz said it best three decades ago in his first series of books, What Went Wrong? “In...

While anhydrous ammonia has many environmental and operational benefits, it is also an extremely hazardous substance that, if accidentally released, presents a significant health hazard because it is corrosive to the skin, eyes, and lungs. Ammonia is also flammable at certain concentrations in air. The Environmental Protection Agency (EPA) would like to work with facilities that have ammonia refrigeration...