Lockout is a life-critical program/process/procedure(s). Our efforts to VERIFY that the program/process/procedures meet our needs is a CRITICAL path in the LOTO process.  OSHA recognized this when it promulgated its Control of Hazardous Energy standard (1910.147).  Specifically, 1910.147(c)(6) “Periodic Inspections” requires the employer to verify the program/procedures and that...

High-hazard Group H occupancies are characterized by an unusually high degree of explosion, fire, or health hazard compared to typical commercial and industrial uses.  There is one common feature about Group H occupancies—they are designated as Group H based on excessive quantities of hazardous materials within the facility/building. Where the quantities of hazardous material stored or used in...

From “facility siting” in a PHA to establishing emergency “assemble areas,” the methodology we use matters.  Many of us use a RAGAGEP from The European Industrial Gases Association (EIGA) titled Methodology for Determination of Safety and Separation Distances.  The “safety distance” is to provide a minimum separation that will mitigate the effect of any...

Today the U.S. Chemical Safety and Hazard Investigation Board (CSB) released its final report on a flammable vapor explosion and fire at the Yenkin-Majestic facility in Columbus, OH, on April 8, 2021. One employee died during the incident, and eight other workers were injured. The CSB’s final report makes several important safety recommendations to Yenkin-Majestics, as well as to professional...

Recently, OSHA cited a global manufacturer for HAZLOC violations using its 1910.307 – Hazardous (classified) locations standard.  We do not see this standard often cited, as in most PSM/RMP citations related to Hazardous Locations (HAZLOC), OSHA and EPA will reference the RAGAGEP NFPA 70.  It is one of our common findings in our PSM/RMP audits at flammable processes; however, our findings...

A global manufacturer of industrial gas could have prevented a May 2023 explosion that severely injured several employees by following required operating procedures in the manufacturing process where diborane — a toxic, colorless, and pyrophoric gas — is produced, distilled, mixed, and transferred. OSHA determined the explosion occurred as a 25-year-old product technician used a heat gun to transfer...

Respondent is an “owner or operator” of the Facility, which produced, used, or stored anhydrous ammonia, a hazardous substance. On April 25, 2019, the EPA conducted an inspection to determine compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, 42 U.S.C. § 9603, and the Emergency Planning and Community Right-to-Know Act (“EPCRA”) Sections...

Respondent has a semiconductor manufacturing process at the Facility. The Facility has three covered processes using silane, ammonium hydroxide (conc 20% or greater), and anhydrous hydrogen chloride, meeting the definition of “process.” Respondent has greater than threshold quantities of anhydrous hydrogen chloride, silane, and ammonia (concentration 20% or greater) in covered processes...

A pharmaceutical and chemical manufacturer and its parent company could have prevented an employee’s fatal injuries from an explosion on May 4, 2023, but lacked the required safeguards in a chemical manufacturing process.  An investigation by OSHA identified numerous deficiencies in the facility’s process safety management program for highly hazardous chemicals for the production and...

Respondent operates a yeast manufacturing facility using anhydrous ammonia. Respondent has on-site for use, 102,420 pounds of anhydrous ammonia. Respondent has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. Respondent has one RMProgram level 3 covered process. On March 2, 2022, the EPA conducted an on-site inspection...

Respondent owns and operates an ammonia refrigeration system at its food distribution warehouse facility (the Facility). EPA inspectors completed an inspection at the Facility on September 27 through September 29, 2021, to evaluate Respondent’s compliance with CAA 112(r). The respondent’s process at the Facility is a covered process that is subject to the requirements of CAPP in accordance with 40...