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Hazards Associated with Flash Freezing Processes (N2 and CO2 OSHA Alert)
Frozen food production can be hazardous to workers. Although nitrogen and carbon dioxide can quickly freeze food products if released into the work area, they can displace oxygen in the air, which can be fatal to workers. Fundamental safety and operational precautions, such as systems to prevent nitrogen and carbon dioxide from entering and accumulating in the work area, alarms to detect low oxygen...
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"Leak Checking" new and modified piping
One of the top questions I get in my process safety circles is… Do we have to pressure test/leak test piping that has been opened/modified before we re-introduce the HHC/EHS to the piping? I turn to one of my favorite sources for RAGAGEPs, NFPA, and one of the best NFPA codes is NFPA 58, which I use as my baseline RAGEGAP for all my flammable liquified pressurized gases. Now, I do take...
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CSB marks the 20th anniversary of the BP Texas City Refinery
The U.S. Chemical Safety and Hazard Investigation Board (CSB) marked the 20th anniversary of the fatal explosions and fires at BP America Texas City Refinery in Texas City, TX, that occurred on March 23, 2005. The tragic incident resulted in the deaths of 15 people and injuries to 180 others.  To remember this deadly event, the CSB released a new report titled “The 20th Anniversary of the 2005...
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3-Way Valve under Hydrostatic RV?
Processes that handle Liquified Pressurized Gases are required to have Hydrostatic Relief Valves on liquid piping where the liquid can be trapped. Much like vapor/gas phase Pressure Safety Valves, it is frowned upon when we have an intervening valve under the PSV. However, many codes today ALLOW us to install a 3-way valve below the Hydrostatic/Vapor/Gas PSV. Interestingly enough, NFPA 58 allows this,...
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Bypass_temp SOP or Car-Seal
Temporary SOP or a Car-Seal or Both?
The arrangement below is very common in processes/systems. This simple yet common arrangement causes havoc in hazard analyses. As the title states, is this arrangement managed with a Temporary SOP, a Car-Seal, or Both? The issue is that the motorized valve is tied to a Hi-Hi level alarm and interlock. When the vessel archives its Hi-Hi level, the interlock CLOSES the motorized valve to STOP flow...
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How many locks do we need to Lockout a Double Block & Bleed arrangement
Several clients design Double Block and Bleed (DB&B) isolation into their process, especially when they know they will regularly enter certain Permit-Required Confined Spaces (PRCS). When these DB&B arrangements are part of the design, the isolation valves and the bleed valve are near one another. This allows us to use a single lock with some cable/chain and lockout devices. … HomeRead...
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LOTO Safety Myth #3 (Training/Inspections)
We often encounter an organization that conducts LOTO training annually. They do this because they believe OSHA requires annual LOTO training. However, the standard, 1910.147, does NOT require annual training! The standard requires each authorized employee to be “inspected” annually. If they fail that inspection, the standard requires the authorized employee to be re-trained. OSHA does...
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Safety Thought of the Week... Culture: An Empirically Based Abstraction
In the past several decades, some organizational researchers and managers have used it to describe the norms and practices that organizations develop around their handling of people or as the espoused values and credo of an organization. This sometimes confuses the concept of culture with the concept of climate, and confuses culture as what is with culture as -what ought to be. Thus managers speak...
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Did we learn from the Stapleton Air Port Tank Farm Fire (1990)
Contributing to the severity and duration of the fire was the lack of storage tank fail-safe control valves and internal fire valves and the location of the control building in the containment area where fuel leaks are likely to occur. The National Transportation Safety Board determined that the probable cause of the fire at the fuel storage facility at Denver’s Stapleton International Airport...
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Nitrogen Cylinder Catastrophic Failure
The rupture of an improperly inspected nitrogen cylinder leads to multiple injuries and equipment damage
Last week I posted the investigation findings from a triple fatality event near my hometown that was caused by a 70+-year-old LPG cylinder that was 33 years PAST its recertification/requalification date AND was overfilled. Now the BSEE has shared a SAFETY ALERT regarding a Nitrogen Compressed Gas cylinder that catastrophically failed injuring three (3) workers and causing property damage. The...
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Oregon OSHA confirmed to be acting within its authority on agricultural labor housing safety, health rules
The Oregon Occupational Safety and Health Division (Oregon OSHA) acted within its authority when it adopted rules strengthening safety and health requirements for agricultural labor housing (ALH), the Oregon Department of Justice (DOJ) has confirmed in written legal advice. The legal advice clears away any potential doubt about the division’s authority to enforce its amended ALH rule, parts...
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Periodic inspection of resistance welding equipment
Section 1910.255(e) requires that a periodic inspection of resistance welding equipment be made by qualified maintenance personnel and that a certification record be generated and maintained. The certification shall include: … HomeRead More »
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