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Processing Facilities and PHMSA Jurisdiction (w/OSHA)
Current Policy PHMSA supports a practice of no gaps/no overlaps. PHMSA has not changed its policy or inspection approach toward processing facilities.  PHMSA has no interest in regulating processing units. OSHA regulates gas processing units. PHMSA and OSHA are in agreement on jurisdictional lines. Neither PHMSA or OSHA are limited by fence lines CLICK HERE for the presentation. CLICK HERE for...
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EPA RMP citations @ potato processing facility (NH3 & $144K)
Respondent owns and operates a potato processing facility which is located, according to the U.S. Census data from 2010, from a few thousand people who live near the Facility. The Facility is located within 0.25 miles of Route 1 and 0.5 miles from the downtown area. Respondent uses anhydrous ammonia in a refrigeration process (“the Process”). On June 25, 2004, Respondent completed its first...
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Questions and Answers from PSM Webinar Sept. 29, 2015 (OSHA’s Directorate of Enforcement)
Questions and Answers from PSM Webinar Sept. 29, 2015.  Answers provided by Jeff Wanko, PE, CSP, and Safety Engineer in OSHA’s Directorate of Enforcement, Office of Chemical Process Safety in Washington, D.C.   Q. Do you have to test the safety equipment annually? A. Under paragraph (j), mechanical integrity, OSHA requires that employers inspect and test process equipment...
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OSHA PSM citations @ propane facility (LPG & $135K)
An OSHA inspection identified several serious and recurring deficiencies in the company’s Process Safety Management program. As a result of these conditions, OSHA cited the facility, the nation’s leading propane supplier, on Sept. 24, 2015, for three repeated and five serious violations of workplace safety and health standards. Proposed fines total $135,000. OSHA found the facility did...
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Learnings from a catastrophic release of 24,000 pounds of methyl mercaptan
There are so many learnings in this incident that every single business should analyze these against their current safety systems.  Many of the issues that the Chemical Safety Board (CSB) investigation investigation identified are present in many other processing units handling Highly Hazardous Chemicals and Extremely Hazardous Substances.  This is a breakdown of the items that the CSB has...
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Side-by-Side comparison of OSHA's PRCS Standards
SAFTENG members can CLICK HERE to download the WORD doc.  
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39 incidents & 1 update (9/27/15)
  Over 12,500 exclusive unsafe acts/conditions and accident/injuries photos and over 1,300 ppt’s & doc’s from more than 2,797 contributors!   Many THANKS to my NEW and RENEWING “Partners in Safety“ since 8/2015  since 7/2015 since 2008 since 2009 since 2013 2015 Fatality Tracker Electrical 34 (2014 =55) (2013 = 32) (2012 = 68) Forklift/Aerial...
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safety alert final wv
FAMOUS Cargo Tank Failure (Safety Alert)
About 11:36 a.m. on January 5, 2002, a tractor pulling a cargo tank semitrailer departed the plant entrance and the trailer catastrophically failed. This failure occurred in the void area between the first and second tank, and the trailer broke into two pieces.      … HomeRead More »
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2015 Photo of the Week #39 (Propane Cylinder, PIT, & Bungee Straps)
 
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2015 Video of the Week #39 (The Last Resort: Vent and Burn - Transport Canada)
 
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FREE Chemical Reactivity Worksheet (NOAA) and 1910.119(d)(1)(vii)
As we know, both OSHA’s PSM and EPA’s RMP rule require us to evaluate the hazardous effects of inadvertent mixing of different materials that could foreseeably occur.  BOTH standards allow us to use our SDS to comply with 910.119(d)(1) Information pertaining to the hazards of the highly hazardous chemicals in the process. The problem is that many SDSs do not adequately address 1910.119(d)(1)(vii)...
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DHS CFATS - Anhydrous Ammonia Top-Screen extension
Question   I am the owner/ operator of a business that maintains Anhydrous Ammonia (AA) at or above the Chemical Facility Anti-Terrorism Standards (CFATS) Screening Threshold Quantity (STQ) for BOTH the treatment of crops and for use as a refrigerant in a cold storage facility. Is my facility eligible to claim the CFATS Agricultural Production Facility (APF) Top-Screen extension? … HomeRead...
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