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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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EPA issues two (2) letters regarding Ammonium Nitrate
EPA issues “letters” on their website that helps clarify many of their rule requirements, much like OSHA’s Letters of Interpretation.  This week OSHA issued twenty-one (21) such letters following their FINAL amendments to their Risk Management Plan rule.  These two (2) letters address what EPA has done to further the safe storage and handling of Ammonium Nitrate and...
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U.S. Court of Appeals for the Fifth Circuit agrees that a control room's positive pressurization unit (PPU) is part of a "covered process" (PSM)
OSHA cited a refinery in 2008 for failing to inspect a piece of equipment known as the positive pressurization unit (PPU). The refinery contends that this citation is unlawful because the PPU is not encompassed by the relevant regulations. Because this dispute involves the interpretation of a binding regulation promulgated by the agency, we defer to the agency’s interpretation if the text is...
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U.S. Court of Appeals for the Fifth Circuit finds that OSHA can't cite for violations that were over 6 months old (PSM)
Delek purchased an oil refinery located in Tyler, Texas from Crown Central and took possession on April 29, 2005. Beginning in February 2008, OSHA conducted a four-month inspection of the refinery and issued a citation on August 18, 2008, finding violations of 29 C.F.R. § 1910.119 and other regulations that are not at issue here. Delek petitions for review of citation Items 4 and 12.  Item...
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Safeguarding our piping (ASME B31.3, Appendix F)
Safeguarding is the provision of protective measures to minimize the risk of accidental damage to the piping or the harmful consequences of possible piping failure.  In most instances, the safeguarding inherent in the facility (the piping, the plant layout, and its operating practices) is sufficient without the need for additional safeguarding.  In some instances, however, engineered safeguards...
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Flanges and their joinment integrity
Three distinct elements of a flanged joint must act together to provide a leak-free joint: the flanges, the gasket, and the bolting Factors that affect performance include the following: … HomeRead More »
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Changes to the 2015 IFC impact “Mechanical Refrigeration” requirements in a BIG WAY
The revisions to 2015 IFC, Section 606.12 clarify the code requirements and add references to two (2) International Institute of Ammonia Refrigeration (IIAR) standards and one American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc. (ASHRAE) standard for design and operation of ammonia refrigeration systems.  This edition of the IFC also pulls in a lot of Ammonia Refrigeration...
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2016 Photo of the Week #52 (Newly NEMA rated switch - NOT)
Can you spot the hazard/code violation?  This is at a fueling station for work trucks at a facility.  This facility has many HAZLOCs so in general, “they should have known better”; but this is what happens when you contract out maintenance to unqualified and untrained contractors.  Work Order said… “Switch at gas pump not working”, this is how it was fi...
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2016 Video of the Week #52 (Scaffolding Collapse)
On Wednesday, surveillance footage captured the moment that a 10-meter-high section of scaffolding, which was carrying three workers, suddenly toppled down in Mianyang city in southwest China’s Sichuan Province.  Seconds after the collapse, some passersby ran to the scene to rescue the workers trapped underneath. More than 20 people eventually joined in to help with the rescue effort. These...
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When BOLLARDS work! (Video)
I have written several times about “vehicle impact protection” for our hazardous materials processes and systems and these articles have garnered a lot of attention, as it seems a lot of folks were not aware there was an actual design basis for these protective members.  Here is a video (WARNING!  MUTE the sound!!) that shows us how these protective members work when DESIGNED,...
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Transferring non-conductive flammable liquids
A major hazard involved with the transfer of non-conductive flammable liquids is the build-up of static electricity with the potential for discharge resulting in fire and subsequent loss of primary containment, an LOPC event. Certain non-polar liquids can be charged (e.g., while flowing through pipes and hoses). Detectable and hazardous charges must be expected if the specific resistance of the liquid...
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EPA's Amended Risk Management Plan Rule (December 2016)
In an effort to provide you with the new language I have presented this material, cut from EPA’s early release document which was several hundred pages.  Here is what is actually changing in the rule: … HomeRead More »
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A breakdown of EPA's amendments to their Risk Management Plan rule (2016)
My good friend and Ammonia Refrigeration PSM extraordinaire, Brian Chapin with RCE, has allowed me to share his work here.  I figured I could not have done any better on this breakdown so I asked if he minded I share this at SAFTENG, we lucked out and he said yes!  This is an excellent breakdown, as he summarizes what has to be done for the new requirement AND provides us with a timetable...
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