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Is your facility REALLY prepared for an emergency? (ERT and PSM SOPs)
Over the past several months we have been working with a confidential client who has afforded me with permission to post this “learning opportunity” for others.  This incident, although minor this time, was recognized as having the potential to end the business so this organization is pulling out all the stops to identify failures.  Once such failure that we have come across deals...
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OSHA PSM citations @ films and packaging manufacturer (Flammables & $112,500)
A plant that produces films used in packaging has been cited by OSHA for 19 PSM related violations. The plant has been cited for exposing workers to flammable chemicals. OSHA has proposed penalties of $112,500. The inspection was initiated in July 2013 under OSHA’s PSM NEP and found employees were exposed to health and safety hazards because the company lacked an appropriate process safety management...
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EPA RMP General Duty Citations @ cold storage warehouse (NH3 & $MILLIONS)
This case may be the “whopper” that sinks the General Duty Clause perverbal teeth into the refrigeration industry.  From all accounts, it appears this facility was inspected and issued some NOVs, which the facility agreed to take care of.  A year later, EPA returned for a follow-up inspection and found items not corrected. Here are the specifics… A cold food storage...
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EPA RMP Citations @ refrigerated distribution center (NH3 and $1K)
On August 10, 2012, EPA conducted a compliance inspection of a refrigerated Distribution Center to determine its compliance with the Risk Management Program (“RMP”) regulations promulgated pursuant to Section 112(r) of the Act, and set forth at 40 C.F.R. Part 68. Based on the August 10, 2012 inspection, EPA has determined that Respondent violated the following regulations: … HomeRead...
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EPA RMP General Duty Citations @ a chemical facility (Flammable Liquids and $22K)
On June 23, 1999, Respondent submitted a Risk Management Plan (“RMP”) for the Facility for the storage of acrolein. Respondent de-registered the RMP from EPA’s national database on July 15, 2010. EPA conducted an inspection of the Facility on August 11, 2010, to assess Respondent’s compliance with Section 112(r)(l) and (7) of the CAA, 42 U.S.C. § 7412(r)(1) and (7). Subsequent...
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60 incidents & 1 update (2/2/14)
  MANY THANKS to my NEWEST and RENEWING Partners in Safety returning partner from 2012 since 2014 since 2013 since 2009 Heartland Technology Partners, LLC made a $500 donation to “Homes for our Troops”!   2014 Fatality Tracker Electrical 4 (2013 = 32) (2012 = 68) Forklift/Manlift 7 (2013=62) (2012 = 52) Mining* 4 2013=87*) (2012 = 92*) *no longer includes China accidents Explosions...
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2013-12-11 07-35-34 436
2014 Photo of the Week #05 (Human Factors)
In the world of process safety, we have a thing called “human factors” and signage is part of this aspect.  Take this sign for example, do you see anything odd about this sign?  Any of the data confusing to you?  Look closely…  By the looks of this photo, this appears to be a “misprint”.  See how the lines are all well centered. 
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2014 Video of the Week #05 (Dangers of 9 Volt Batteries PSA)
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Vibration-induced fatigue on process pipework
What happened? During a recent inspection at a facility, an NOPSEMA inspector observed vibration-induced fatigue cracking and evidence of rectification work carried out on several small-bore connections on seawater cooling pipes. On further investigation, it was discovered that there had also been a recent fatigue failure on the hydrocarbon test separator header. Fortunately, the operator had detected...
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Are we "dumbing" down RAGAGEPs to make OSHA's job harder?
Early last year I wrote about some trade organizations that were “revising” their codes/practices, which in turn were making them “more flexible”.  I stated it then and I will state it again, this time along with the US Chemical Safety Board… this is a REALLY BAD idea.  Both OSHA and EPA wrote “performance oriented” standards for process safety.  This...
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API provides OPEN/FREE access to many of their codes/practices
Ever wanted to know what an American Petroleum Institute (API) code or practice said?  Well now you may be in luck; as API is providing online public access to many of their key industry standards, including a broad range of safety standards, most of which were previously only available by purchase. These standards will be available as “Read Only” access and API will host these documents...
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How rigorous is your contractor safety evaluation(s)?
Recently the SAFTENG team was hired to provide some safety services during a turn-around/shutdown at a PSM/RMP facility . While out and about we came across a very interesting find… a speciality contractor with facial hair. Now this was not just any speciality contractor and the reason we were so surprised was the facility had, what we thought, a very rigorous contractor safety program. The speciality...
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