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July 6, 2025
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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July 6, 2025
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…
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July 6, 2025
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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July 6, 2025
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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July 6, 2025
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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July 6, 2025
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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July 6, 2025
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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July 6, 2025
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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July 2, 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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June 29, 2025
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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June 29, 2025
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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