The Dirty Dozen highlights the most frequently observed human-related issues discovered during Fiscal Year 2022 agency mishaps and close-call investigations. Throughout the year, these issues contributed to $3,310,298.74 in damage costs and 630 workdays of lost time. … HomeRead More »

In Reason’s Swiss Cheese model, there are four “slices “or tiers of human error potential, divided into two sections: an “active” layer and “Latent Factors”: preconditions, Supervision, and Organization. The goal of the Human Factors Analysis and Classification System (HFACS) is to understand human factors throughout the system rather than stopping at the operator. Most mishaps can be connected...

This is a reminder that if your ERP or Environmental Management System (EMS) has not been updated to reflect these “NEWER” CSB reporting requirements, the facility should consider updating these programs/processes and including the reporting requirements in EHS training. Also, line 9.8 of your RMP should list 40 CFR 1604 – Accidental Release Reporting. The U.S. Chemical Safety and...

This is just an FYI to my Cl2 clients. Although the changes are NOT significant (0.1 – 0.3 miles), they are indeed changes to the Downwind Protective Action Distances. If you have used the 2020 ERG Distances in your Pre-Plans, which you or I did for your Emergency Response Plan (ERP), it may be beneficial to update them. REDUCED distances are highlighted … HomeRead More »

This is just an FYI to my NH3 clients. Although the changes are NOT significant (0.1 – 0.2 miles), they are indeed changes to the Downwind Protective Action Distances. If you have used the 2020 ERG Distances in your Pre-Plans that you or I did for your Emergency Response Plan (ERP), it may be beneficial to update these pre-plans/ERP. REDUCED distances are highlighted … HomeRead More &...

One of the many changes to the 2024 ERG, includes considerations for lithium battery and electric vehicle (EV) fires fire control.  NOTE: the print editions are NOT yet available, but we can download the app (CLICK HERE)   Water spray cools batteries and helps suppress and slow the release of toxic gases but does not stop the chemical reaction (thermal runaway). Other extinguishing agents...

The Respondent formerly operated an ammonia refrigeration process at a distribution center and warehouse, which maintained a maximum inventory of the regulated toxic substance anhydrous ammonia at the Facility, which exceeds the threshold quantity of 10,000 pounds of anhydrous ammonia as set forth in Table 1 at 40 C.F.R. § 68.130 and, therefore, has had a regulated substance present in more than a...

Are “safety cans” created equally?  Nope, and which UL standard they meet will dictate how much “safety they provide.” OSHA’s 1910.106 defines a “safety can” as Safety can shall mean an approved container, of not more than 5 gallons capacity, having a spring-closing lid and spout cover and so designed that it will safely relieve internal pressure when...

A Y-shaped strainer (filter) in a three-inch pipe ruptured. The failure occurred after pressure cycles induced by thermal expansion. The released isobutylene resulted in a gas cloud explosion and the company’s bankruptcy. Aspects: When a closed system filled with a liquid hydrocarbon raises the temperature, the pressure can rise above the design. Here, a brittle fatigue failure occurred in the...

Have you ever walked up to a atmopsheric storage tank and seen the paint bubbling and the hazard signs/placards faded/peeling off?  Look up and you will most likely see the atmopsheric vent line on that side of the tank.  What are these indicators of?  The tank being over filled, which is a serious event and is certainly a Loss of Primary Containment (LOPC) event.  But these days,...

Although it is done often, most state Fire Codes PROHIBIT the use of DOT tank vehicles and tank cars as “Flammable Liquid Storage Tanks.”  We call this “dropping trailers,” and my 2014 Article “Dropping Trailers of Flammable Liquids” got quite the debate going.  But trust me, there are sound engineering reasons why we can not and should not use DOT shipping...

Recently, a facility experienced firsthand why the IFC and its state fire code PROHIBIT the movement of hazardous materials via the facility’s “tunnel system.”  The code does not prohibit the use of the tunnel system or even in enclosed corridors. Still, the design requirements for these tunnel systems or enclosed corridors to move HAZMATs are usually not cost-effective. ...