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350 pound NH3 release @ potatoe processing plant leads to $65K in EPCRA citations
Respondent produced, used, or stored ammonia at the Facility and released a reportable quantity of an EHS, ammonia. On or about August 31, 2022, a “release” of ammonia in excess of 100 pounds occurred at the Facility (the release). As a result of the information obtained by the EPA and subsequent investigation, the Complainant has determined that the Respondent has violated the reporting...
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Failure to update RMP is more than 68.190 violation!
I see numerous RMP citations for businesses failing to update its RMP submittal every five years. And the EPA will issue a single citation using 68.190. One day, I hope the EPA will take this a step further and issue another citation against 68.15… … HomeRead More »
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EPA RMP Citations @ chemical manufacturer (Isobutane & $4K)
I normally do not share cases that are handled as Expedited Settlement Agreements (ESA) but this one incldued three (3) very common findings during our PSM/RMP audit, so I am sharing this case: At the time of the inspection, pipes containing isobutane located at the isobutane tank farm and pipes containing isobutane located in the vault area outside the fencing were not properly labeled to indicate...
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Risk Models (Feeding the Lion)
Since I was a student in safety at MSU, there has been a “Risk Model” that depicts a zoo worker feeding a lion in its cage. This model has been revised many times, but it does a great job of providing a visual display of how risk can change based on how the “system” is engineered. However, the most recent version of this model indicates a “Zero Risk” level. I...
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Bypassed Safety Device Deficiencies (BSEE)
A team of auditors identified a potential risk associated with bypassed safety devices and inconsistent interpretation of regulations after multiple incidents of noncompliance were issued, associated with the operator’s failure to comply with 30 CFR 250.869 and 30 CFR 250.870 in 2025. The BSEE Performance-Based Risk Inspection (PBRI) covered five assets (all production platforms) in the GOAR, which...
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Fatigue Cracking of ¾-Inch Pipe Nipple Results in Gas Release (BSEE)
The Bureau of Safety and Environmental Enforcement (BSEE) has investigated a recent offshore gas release incident resulting from the failure of a ¾-inch pipe nipple connected to a compressor suction scrubber (Figure 1). The failure led to an immediateplatform shut-in and a full muster of personnel onboard. The released gas posed a significant safety risk, particularly due to its proximity—within...
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NSC's FREE Maturity Assessment and Action Plan
The NSC Safety and Health Maturity Assessment is a free tool that helps organizations identify where they are on their safety journey and offers next steps to improve safety. Please take 15 minutes to complete the assessment, then share your feedback via a short survey. CLICK HERE
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Benzene Railcar on fire in derailment (a lot to look at)
When you see it… Flammable liquid railcar, in fact, it’s a carcinogenic flammable liquid, a Benzene railcar on fire. I know it’s hot as heck in MS this time of year, but dang: placement of the truck and FF’s in what is clearly the hot zone placement of the FF using a hand line in the line of fire placement of the FF UNDER the RCar that’s teetering on the tacks and lack of...
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EPSC Learning Sheet July 2025
Consider Human Error and Domino Effects (EPSC Learning Sheet July 2025)
At an Ethylene unit in the Czech Republic (2015), when swapping over cooling water supply lines during a flowmeter calibration, the operator made a simple mistake. While intending to open valve #3 on the spare supply line, he closed the identical valve #2 instead, shutting off all cooling water to the Light Ends columns. A rapid chain of events ensued. The propylene column was over-pressured,...
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OSHA regulatory activities on 7/1/25
OSHA announced changes to the following standards: … HomeRead More »
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How can I tell if a facility is doing their SCBA inspections "by the book" each month?
A trick question I learned long ago, when it was used on me, is one I use today when auditing a facility that has SCBAs for “Emergency Use Only” (e.g., an ERT). As we are walking to the ERT cage/trucks, I casually ask if the facility fills its bottles/cylinders or if they have a breathing air compressor and fill their own bottles/cylinders. Many of my clients use their Local FD to fill...
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IDLH Value Profile: Hydrogen Bromide CAS® No. 10035-10-6
This technical report presents the scientific basis, toxicologic data, and risk assessment meth­odology used to derive a health-based immediately dangerous to life or health (IDLH) value for hydrogen bromide (CAS No. 10035-10-6). The IDLH values are based on the scientific rationale and logic outlined in Current Intelligence Bulletin (CIB) 66: Derivation of Immediately Dangerous to Life or Health Values...
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