EPA and OSHA put out an Alert in 2007 regarding the use of Excess Flow Valves (EFV) as a “safeguard”.  Although that alert has been “archived” the failures we see today align with what that alert warned us about 16 years ago!  While excess flow valves (EFV) are in extensive service and have prevented numerous pipe or hose breaks from becoming much more serious incidents,...

SAFETY ALERT From National Propane Gas Association (NPGA) INTRODUCTION: Readers of this bulletin should consult the law of their individual jurisdictions for codes, standards and legal requirements applicable to them. This bulletin merely suggests methods which the reader may find useful in implementing applicable codes, standards and legal requirements. This material is not intended nor should it...

While wrapping up a 2023 project, I was saddened to see the image below while in the OSHA incident database.  Several things come to mind regarding these H2S incidents: 1) no other chemical in the database has this deadly percentage over the past three (3) years 2) Hydrogen Sulfide has GREAT warning properties (odor threshold 0.008 to 0.1 ppm), but with that also comes Olfactory Fatigue (@ 100...

At 8:00 a.m. on June 26, 2022, two (2) employees emptied and cleaned an open-topped frack tank (Tank #4) at an oil and gas services site. There were no eyewitnesses, and the employees were working at a remote site alone, so few details are known about what occurred. At the time of the investigation, hydrogen sulfide (H2S) gas was detected at levels between 3 parts per million (ppm) and 5 ppm, which...

For those who live within the process safety bubble, you know all about the MOC “requirements” from OSHA and EPA process safety standards.  However, an MOC program is vital to any formal Safety Management System.  And you would be correct to say “OSHA (nor EPA) does not require one outside a PSM/RMP standards.  But after a busy year helping clients with both traditional...

One of my all time favorite RAGAGEPs is the Compressed Gas Association’s (CGA) 2.1 for those who handle anhydrous ammonia.  This year, they published the 7th Edition, and they made it even better.  Unlike so many RAGAGEPs, the CGA embraced the practice of “Continuous improvement” and really did a nice job with their additional explanations of their existing requirements. ...

This is a really good case to read.  It involves light-curtains and lasers as “guarding” and the fact that they were not functioning.  One of the machines had broken a manager’s foot when he/she entered to troubleshoot a problem (LOTO citation).  The facility had put tape on the floor as an indicator rather than fixing the guarding.  The Willful citation was due...

The men were helping to build a new sewage pumping facility. They were in a concrete foundation, a trench-like part of the structure about 40 feet deep. Sources said giant intakes five feet in diameter are inside the structure. Inflatable plugs secured with chains are used to keep the water out. Some sort of catastrophic failure immediately sent sewage water into the space where the men were working...

This material is from the United States Coast Guard (USCG) and is an EXCELLENT explanation of the required electrical markings/labels on tools/equipment used within a Hazardous Location. Simply put, if the tool/equipment is NOT marked/labeled for use in the specific HAZLOC, it can NOT be brought into the HAZLOC. … HomeRead More »

On May 15, 2021, an incident resulted in the fatality of an offshore worker when two production personnel were pressure testing a 16-inch well surface casing and anexplosion occurred. The explosion entailed a high-pressure release with no signs of ignition.  Information obtained by BSEE during the subsequent investigation determined that personnel were using a high-pressure well to supply the...

Respondent has a liquid natural gas pretreatment process at the Facility, meeting the definition of ” process” as defined by 40 C.F.R. § 68.3. Respondent receives natural gas by pipeline and pretreats the natural gas to remove carbon dioxide, sulfur compounds, water, mercury, and heavy hydrocarbons. The regulated substance under 40 C.F.R. Part 68 Chemical Accident RMP regulations is Natural...

Respondent is the owner and operator of an oil refinery. On September 9-13, 2019, the EPA inspected the Facility to determine compliance with 40 C.F.R. part 68. Based on the observations of the EPA inspectors at the inspection, the EPA has determined that Respondent uses, handles, and/or stores more than the threshold quantity of Flammable Mixture, Hydrogen flouride/Hydrofluoric acid, Butane, Isobutane,...