R 408.17313 Proper use, handling, storage, and containment of firefighting foam concentrate. Rule 7313. … HomeRead More »

On or about January 31, 2023, representatives of the EPA inspected Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had over 10,000 pounds of anhydrous ammonia in a process at its facility. Information gathered during the EPA inspection revealed that Respondent stores, distributes,...

The criteria for determining when to retire or repair FR clothing/garments/accessories MUST provide measurable or easily identifiable damage. The following are some means to DEFINE and QUANTIFY these deficiencies: … HomeRead More »

“People are actually very reliable, but there are many opportunities for error in the course of a day’s work, and when handling hazardous materials, we can tolerate only very low error rates (and equipment failure rates), lower than it may be possible to achieve. We may be able to keep up a tip-top performance for an hour or two while playing a game or a piece of music, but we cannot keep...

“People are actually very reliable, but there are many opportunities for error in the course of a day’s work, and when handling hazardous materials, we can tolerate only very low error rates (and equipment failure rates), lower than it may be possible to achieve. … HomeRead More »

In 2023, I began taking issue with the condition of Flame Retardant Clothing (FRC) being used in REQUIRED areas and tasks.  We see garments that in no way would pass a “routine inspection” per NFPA limitations.  My go to RAGAGEP for this is NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Short-Duration...

A Health and Safety Executive (HSE) investigation into a gasoline overfill of a carbon adsorption vapor recovery unit (VRU) revealed concerns with the design of the VRU. The overfill prevention system was NOT independent of the basic process control system (BPCS).  When the BPCS failed the overfill prevention system also failed. This resulted in loss of containment and risked a significant fire,...

OSHA’s PSM standard is over 30 years old, and EPA’s RMP standards/rule is approaching its 30th birthday fast.  They are so 20th century (LOL)!  This article is about how some of my clients are approaching their 3-year audits required by both standards.  This approach embraces the “audit element” of the process safety management system as genuinely intended: a...

If management believes safety is all about workers behaving as they have been trained, then we should be able to save thousands of dollars by ordering keyboards with no “delete” button. After all, if we expect workers to make no errors, mistakes, or violations in executing their jobs, we should have the exact expectations within management personnel carrying out their duties. We ALL make...

The value of a Root Cause Analysis and Corrective Action Plan process to a business If the critique process is effective and an organization successfully determines why the event occurred, the appropriate corrective action can be achieved. The avoided cost associated with recurrence and improvement in performance is the organization’s dividend. … HomeRead More »

Respondent owns and operates a chemical warehouse and repackaging facility. From November 2 through November 5, 2021, EPA performed an inspection of the Facility to evaluate compliance with Section 103 of the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”), EPCRA Sections 304-312, and CAA Section 112(r). Based upon the information gathered during the Inspection and subsequent...

We have discussed the hazards of pneumatic pressure testing many times.  Pneumatic pressure testing should be a “last resort” for pressure testing process equipment.  But for those who question the degree of hazard this REQUIRED test brings about, here is something to consider.  Take a look at the following comparisons between the stored energy in piping systems and the equivalent...