The use of Standard Operating Procedures (SOPs) helps to reduce the risk of injuries and fatalities by providing written guidance to team members and responders with established safe procedures for actions to be taken during a wide variety of incident responses. They provide direction for team members and responders on what they need to do to safely perform job tasks that are routine and predictable....

This is a long time coming.  OSHA referenced the use of EPCRA’s Tier II’s in this section; something that has been in place since 1986!  For those of you who have stressed over my lengthy and detailed PSM/RMP audit findings regarding emergency planning and response – you’re welcome.  Closing out those findings means you are well on your way to being compliant...

During emergency incident operations, team members and responders face the most challenging aspects, both physically and psychologically, of their vocation.Ensuring safe operations at incidents can reduce team member and responder injuries and fatalities and limit exposure to health hazards. Paragraph (p) of the proposed rule is based on current industry practices, as reflected by NFPA consensus standards...

Proposed paragraph (i) provides requirements to ensure that Workplace Emergency Response Employers (WEREs) facilities are safe for team members. Paragraph (i)(1)(i) of the proposed rule would require WEREs to ensure their facilities comply with 29 CFR 1910 Subpart E, Exit Routes and Emergency Planning.  This proposed provision is not a new requirement because WEREs are already required to comply...

As noted in the Summary and Explanation for proposed paragraph (a) Scope, the proposed rule would not apply to any employer that is not an Emergency Service Organization (ESO) and does not have a Workplace Emergency Response Team (WERT). Nothing in this proposed rule would require an employer to establish a WERT. Each employer makes the decision for itself, based on a risk assessment of its facility,...

In the world of hazardous materials, evacuating them from their primary (and secondary) containment system plays a KEY role in performing maintenance/servicing on the system SAFELY.  For example, opening a process/system that contains hazardous materials FIRST has to be evacuated of that hazardous material, and this evacuation to a “safe place” should be done through a Manual “Spring-Loaded-CLOSED”...

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. ...