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I am proud to announce that SAFTENG and The Chlorine Institute have renewed our partnership for another year (through 2026).  Members of The Chlorine Institute receive a FREE SAFTENG membership.  If you qualify, please contact me

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OSWER Risk Management Program Evaluation Scoping Project (EPA’s path forward in determining who should get an RMP inspection)
  The Risk Management Program (RMP) is implemented by the Office of Emergency Management (OEM) in EPA’s Office of Solid Waste and Emergency Response (OSWER). EPA and state and local implementing agencies conduct inspections at RMP facilities to determine compliance with RMP regulatory requirements, but because resources for conducting inspections are limited, within the past few years EPA...
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CAA 112(r) Inspections - What to expect & suggestions from the inspectors
This is an EXCELLENT presentation from EPA (4/2013) on doing RMP Inspections @ Ethanol Facilities. Although the presentation appears to be specifically for Ethanol facilities, it’s “suggestions and tips” WILL apply to any RMP covered facility (and for PSM-covered facilities as well). Some of the interesting revelations are: 1) EPA uses Google and Bing Satellite images in their screening...
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EPA’s Office of Inspector General says Improvements Needed in EPA Training and Oversight for RMP Inspections
This is why I have oh little faith in our government to protect us!!!  Enforcement can NOT and should NOT be the driver behind improved environmental, health and safety performance!  The hypocrisy in this report, aimed at the agency tasked with enforcing the very rule they wrote is nothing short of pathetic.  Sitting here I look back at all the RMP citations that have been issued to...
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Pipeline fails because deteriorated coating, ineffective cathodic protection, and the failure to detect the corrosion because the pipeline was not inspected or tested after 1988
Does your process have any “underground piping”?  We do not see this design in newer process designs, but in years past – putting pipe underground seemed like a good idea.  This NTSB report does an excellent job of breaking down the failure modes of underground piping.  The National Transportation Safety Board determined that the probable cause of the pipeline rupture...
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2014 Video of the Week #11 (Chlorine Leak)
An oldie but a goodie, showing how chlorine, with a VD>2.5 acts during a release (i.e. stays on the ground).  On August 14, 2002, a chlorine transfer hose ruptured during a rail car (90 ton) unloading operation at a chlorine repackaging facility near Festus, Missouri. The hose rupture ultimately led to the release of 48,000 pounds of chlorine, causing three workers and 63 residents to seek...
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villageidiots
2014 Photo of the Week #11 (Confined Spaces)
Another team of UNTRAINED, or TOTALLY IGNORANT but trained, workers doing their version of confined space entry.  This is for those who provided negative comments on my other “entry photo”.  This is good ole USA safety – NOT some third world country.  And by the way, the workzone traffic management is a pathetic effort as well. 
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Basis for EW/SS locations?
I was doing some research for as client and came across this information, which I think is something many of us have been struggling with. The source is MN-OSHA, which is a state OSHA plan and these plans can be MORE stringent than federal OSHA – but they can NOT be lesser. Which means that if we comply with this guidance and we work in a Fed OSHA state we should be on some solid compliance ground....
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OSHA cites Frozen Food Manufacturer, Refrigeration Maintenance Contractor, and Staffing Company (NH3 Refrigeration & $264,360)
This is a very interesting citation!  OSHA issued citations to three (3) DIFFERENT organizations from the same inspection at a frozen foods plant. They cited the host company, a contractor who provides maintenance services for the refrigeration process, and the temp staffing agency that provided temp employees who worked in the plant.  Not sure how this will all work out, but it is an interesting...
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AZ-OSHA SCAM ALERT
The Industrial Commission of Arizona (“Commission”) has received inquiries concerning a “Final Notice” document that has been received in the mail from the “Labor Standards Compliance Office” with an address of East Thistle Drive in Phoenix, Arizona. This document, believed to be a sales solicitation or advertisement, states that there is a fee of $295.00. The document is crafted in a manner that has...
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AK-OSHA Review Commission's Decision on whether a “Fish Bin Chiller Alley” at a seafood processing plant is a Confined Space/PRCS
Alaska’s Occupational Safety and Health Review commission hands downs a PRCS decision regarding a “Fish Bin Chiller Alley” at a seafood processing plant.  A CSHO stated this corridor, meeting the criteria below, was not only a CS, but it was a PRCS: corridor approximately 60 feet long and 5 feet wide within the corridor there are five (5) chiller units and a network of pipes that provides chilled...
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Lockout is the RULE, “minor servicing” is the exception
As human nature goes, we know if we give an inch, some will take a mile. This belief could not be more real than in Lockout/Tagout and the “Minor Servicing” exception. The “rule” is to LOCK IT OUT, and the “minor servicing” exception is just that, an exception to the rule. OSHA has set the bar pretty high for what we can claim as “minor servicing,” and this article looks to dispel the myths...
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OHEPA TierII
(UPDATED on 3/10/14) Friendly Tier II reminder for Ohio facilities (FD/LEPC Approval Signature)
2014 is a big year for changes in the EPCRA Tier II Reporting, which by the way is due by March 1st.  This year, OH EPA (and I am sure OH is not the only state) is now requiring the person responsible for the Tier II forms to obtain an “approval signature” from the responding fire department OR an LEPC representative.  On page 13 of OH-EPA’s Facility Reporting Compliance Manual it...
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