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Ammonia refrigeration processes below 10K MUST STILL meet ANSI/ASHRAE 15 Engineroom Ventilation
This is not the first time I have addressed this matter. Still, somehow, somewhere, a dirty little lie has been circulating among ammonia design and installation contractors that somehow an engine room handling less than 10,000 pounds of anhydrous ammonia (NH3) is incapable of presenting an explosion hazard, thus no need for any engineered ventilation.  This is insane logic and not anywhere near...
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Relief Valve Maintenance & Testing
Some specialized literature regarding the maintenance of safety relief valves (SRVs) is available, but it is best to always consult the manufacturer’s detailed installation and maintenance manuals on the subject, as some type of valves might require special attention. It is highly recommended to always use genuine manufacturer’s spare parts. In some parts of the world, this is even required...
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When the "Employee Participation" ain't what its cracked up to be!
Almost all Occupational Safety and Health efforts need one key ingredient to be successful… Employees participating in the safety process!  Heck, OSHA and EPA have even regulated employee participation (EP) in their process safety standards.  But far too many organizations have not quite understood the concept of Parent-to-Parent engagement vs. Parent-to-Child engagement and almost...
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Bonding and Grounding of plastic containers during the dispensing or transferring of Class I flammable liquids (OSHA)
The requirements for bonding and grounding of containers during the transfer of Class I flammable liquids are contained in 29 CFR 1910.106(e)(6)(ii). This paragraph does not specifically address plastic containers. However, OSHA issued “OSHA Instruction STD 1-5.14-A” on October 24, 1980 to address plastic containers (NOTE: this STD is NO LONGER AVAILABLE via OSHA.gov). This instruction...
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Illinois EPA refers Ellinor Trucking to Attorney General for enforcement
Illinois Environmental Protection Agency Director has asked the Illinois Attorney General’s office to proceed with enforcement action against Ellinor Trucking and River Rock Logistics, operated out of Lanark. The Illinois EPA alleges an inadequate transfer hose was used when an Ellinor employee prepared to offload anhydrous ammonia to an above-ground storage tank, which resulted in the release...
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Replacement in Kind... is it really?
Following the guidance of OSHA and EPA, the industry has attempted to simplify what type of change requires the initiation of the Management of Change system and which type of change is a “replacement in kind” (RIK).  Oddly enough, both OSHA and EPA chose not to define the meaning of “change”; instead, they have officially defined what a “replacement in kind”...
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Fleming culture ladder
Safety Culture Maturity model - FSCMM (Fleming)
The elements that form the safety culture maturity model have been adapted from the safety culture components listed by the HSE in Reducing error and influencing behavior – HSG48.  It is unlikely that these elements will map precisely onto the factors that companies have previously measured in safety culture or climate surveys because there is considerable variation in the proposed elements...
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Pressure Test gone bad! (Tank Launched)
On January 26, 2006, a factory in Brazil witnessed a significant accident during a pneumatic pressure test involving a tank and pipework. The incident occurred because blind flanges were not used to isolate the pipework connected to the tank. Instead, only the valves were closed. This oversight led to the possibility that one or more valves failed or were not fully closed, leading to the tank itself...
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What are Public Exposure Guidelines?
Public exposure guidelines are intended to predict how members of the general public would be affected (that is, the severity of the hazard) if they are exposed to a particular hazardous chemical in an emergency response situation. The most common public exposure guidelines are: AEGLs (Acute Exposure Guideline Levels) ERPGs (Emergency Response Planning Guidelines) TEELs (Temporary Emergency...
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What are Protective Action Criteria for Chemicals (PACs)?
Protective Action Criteria for Chemicals (PACs) dataset is a hierarchy-based system of the three common public exposure guideline systems: AEGLs, ERPGs, and TEELs. A particular hazardous substance may have values in any or all of these systems. The PACs dataset implements the following hierarchy when choosing which values to use for the PACs: Final, 60-minute AEGL values Interim,...
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What are Temporary Emergency Exposure Limits (TEELs)?
Temporary Emergency Exposure Limits (TEELs) are guidelines designed to predict the response of members of the general public to different concentrations of a chemical during an emergency response incident. Note: TEEL values are NO longer included specifically in ALOHA, see PACs. TEELs estimate the concentrations at which most people will begin to experience health effects...
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What are Acute Exposure Guideline Levels (AEGLs)?
Emergency response personnel may have never heard the acronym AEGL, but that doesn’t mean it does not play a major role in the decision making process at almost all emergency responses to hazardous materials.  AEGL’s and ERPG’s are the most widely used exposure guidelines in emergency responses to hazardous materials.  In fact, did you know the DOT Emergency Response Guidebook...
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