The Program 3 prevention program requirements under 40 CFR Part 68 are almost identical to the requirements of OSHA’s process safety management (PSM) standard. OSHA exempts certain industries from the PSM standard. Why does EPA not exempt those same industries from the CAA §112(r) risk management program requirements? … HomeRead More »

When selecting the worst-case release scenario for Program 2 and 3 processes as required by 40 CFR §68.25, a stationary source owner or operator must analyze the release scenario that results in the greatest distance to an endpoint. Does the “greatest distance to an endpoint” refer to the greatest total distance from the process (e.g., vessel or pipeline), or to the distance beyond the...

The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness. … HomeRead More »

For me, SIF is just using Process Safety Management (PSM) tools for lower-frequency, higher-severity events, whereas traditional “recordable injuries” can be managed with the traditional Safety Management System (SMS). But here is the catch… the consequence may be more severe (serious), but the failures that led to those consequences can all be traced back to the failure of our Controls/Barriers/Safeguards...

Heinrich did not blame workers for accidents—quite the opposite. He was more in the camp of Latent Organizational Failures, as James Reason taught us in the 1980s. In this passage from his 1928 article “The Origin of Accidents”, Travelers, we can see his position on accidents on full display… Remember, he said this 96 years ago!!! … HomeRead More »

In April 2023, EPA published a report on the first survey conducted of the State Emergency Response Commissions. The purpose of the survey was to learn how the Emergency Planning and Community Right-to-Know Act is currently implemented at the state and local levels, as required by the 1986 legislation, as well as its amendments of certain provisions in 2018. State Emergency Response Commissions are...

On Dec. 3, 2004, a 50,000-pound steel pressure vessel violently exploded at the southwest Houston Marcus Oil and Chemical facility. The pressure vessel contained flammable hydrocarbons such as hexane. The pressure vessel was a horizontal tank 12 feet in diameter, 50 feet long, and operated at a pressure of approximately 67 psi. Marcus Oil did NOT use a qualified welder or proper welding procedure to...

On September 13, 2007, a subcontractor was implementing a hot tap into a carbon steel pipe. The explosion was caused by the heat from the acetylene torch kindling the residual vapor inside, attaching to the polyvinylchloride (PVC) piping. Shrapnel pieces were blown up to 100 feet outwards due to the force of the explosion. The two workers who were closest to the explosion were guarded by an alcove...

On January 15, 2008, a pressure vessel at a New Jersey foundry exploded, killing one 60-year-old worker instantly while injuring eight other workers with shrapnel. The pressure vessel in question was used to pressurize/depressurize molten aluminum to prevent/eliminate porosity from the metal. The incident occurred while two (2) workers, including the one who was killed, were testing a new O-ring gasket...

In June 2008, a cylinder was dropped, and its top valve hit a concrete platform. The impact of the cylinder valve on the concrete caused the threads on the screw connection, which held the valve on the cylinder, to fail, resulting in complete separation of the valve from the cylinder. The cylinder’s internal pressure was 600 psig. The combination of pressure and size of the cylinder hole caused it...

At 11:30 p.m. on March 19, 2009, Solus Industrial Innovations LLC employees from the third shift had just come to work. Their employer is a manufacturer of plastic conveyor parts. One employee (Employee #1) pointed out to the on-shift supervisor that there was a pool of water near an 80-gallon water heater that was being used to supply heating water to the production process. Minutes after this exchange,...

In May 2009, a compressed air tank failed, blowing the bottom off of the tank and sending fragments flying into a concrete wall, puncturing the wall. The investigation following the incidentrevealed several serious problems with the condition of the tank, including severe corrosion and rust at the bottom of the tank, where it failed, and an improper weld repair which had been made to the tank at some...