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I am proud to announce that SAFTENG and The Chlorine Institute have renewed our partnership for another year (through 2026).  Members of The Chlorine Institute receive a FREE SAFTENG membership.  If you qualify, please contact me

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Is "grounding" or "bonding" or BOTH "grounding & bonding" to safely transfer flammable liquids?
I am sure this article will ruffle a few feathers, but honestly, I am surprised and disappointed by that. But I do a lot of work in flammable liquid processing, and this topic always comes up during audits, PHAs, and accident investigations. Some folks will swear that only grounding is “required.” They get this from OSHA’s 1910.106(e)(6)(ii) Grounding section. However, although...
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Corrosion Rates and Remaining Life/Fitness for Service
Source Corrosion Rate or Degree of Corrosion Remaining Life or Fitness for Service Application API 570 Long-term (between last and initial inspections):   (use corrosion rate resulting in shortest remaining life) Piping Short-term (between last and previous inspections): Piping and Vessels NBIC – 23 a) calculated from data collected by owner or...
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Comparison of Piping Inspection Requirements in Refrigeration Industry
Comparison of Piping Inspection Requirements in Refrigeration Industry Code Component Description Inspection Remediation Inspection Frequency IIAR 109 (1997) Uninsulated Pipe (4.7.4)   Examine for corrosion Clean pipe down to bare metal and paint with rust preventative paint. “Badly corroded pipe should be replaced.”  (4.7.4) – Annual ammonia safety...
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Comparison of Pressure Vessel Inspection Requirements in Refrigeration Industry
Comparison of Pressure Vessel Inspection Requirements in the Refrigeration Industry Code Type of Inspection Component Description Inspection Remediation Inspection Frequency IIAR 109 (1997) All pressure vessels If signs of more than mild corrosion should inspect further by a professional engineer or ASME inspector (4.3.5) None listed – Annual ammonia safety...
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Summary of the RMP Chemical Exemptions
The following are all the “exemptions” permitted in EPA’s Risk Management Plan rule (40 CFR PART 68—Chemical Accident Prevention Provisions) … HomeRead More »
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Knowing your Pressure Vessel Stamps/Forms
In process safety, we deal with a lot of pressure vessels and even some boilers. It took me years to understand the differences between the U-1, P-2, and P-3 forms and all the requirements for the placement and management of these pressure-retaining containers. This article is intended to help safety pros who may have to deal with these types of pressure-retaining containers; so this is a 30,000-foot...
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OSHA's position on Hydrostatic Relief Valves and Ammonia Refrigeration Processes
Below is OSHA’s official position on the need for hydrostatic relief valves in an Ammonia Refrigeration process.  This is a bold move on OSHA’s part as the Ammonia Refrigeration industry and their trade groups have consistently stated that a “trained operator” is better than a hydrostatic RV. (emphasis added by me) … HomeRead More »
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Normal Respirator Use vs. Emergency Response Team use
I recently worked with a client on their emergency response efforts, and we continue to find businesses that do not understand the different requirements of qualifying a worker to use a respirator under CONTROLLED workplace exposures vs. UNCONTROLLED emergency response exposures.  So, I wanted to write this article to make it as straightforward as possible… Employee A is hired into a job...
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Barrier Analysis Worksheet
Accident Investigation - Barrier Analysis
When analyzing barriers, investigators should first consider how the hazard and target could come together and what was in place or was required to keep them apart. Obvious physical barriers are those placed directly on the hazard (e.g., a guard on a grinding wheel); those placed between a hazard and target (e.g., a railing on a second-story platform); or those located on the target (e.g., a welding...
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Human Factors Engineering - Center High-Mounted Lamps
One of my favorite examples of Human Factors Engineering is the Center High-Mounted stop Lamps.  We have all seen them on every personal vehicle manufactured today.  They are now a safety requirement.  But it was not always that way.  So, what is a CHMSL?  CHMSL are red stop lamps mounted on the center line of the rear of a vehicle, generally higher than the stop lamps on the...
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How does OSHA and EPA define "retail establishment" in regards to their "exemptions" from PSM/RMP
Retail facilities are exempted from PSM requirements.  At first glance, it appears this is a pretty broad exemption, as the standard just states. This section does not apply to:1910.119(a)(2)(i) Retail facilities; But as I wrote about last month, not all retail facilities selling a PSM Highly Hazardous Chemical (HHC) in the USA are exempt. In 2010, the state of Oregon began covering retail businesses...
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EPA's RMP and Program 3 NAICS #'s
As we have discussed before, the EPA broke down its RMP rule into three (3) programs, and each program has criteria that will place the process in one of the three. However, the one criterion that confuses some businesses is how the EPA used the North American Industry Classification System (NAICS) to qualify a process for Program 3. Here is what the RMP rules state. … HomeRead More &ra...
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