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When you see it... Flange Jumpers for Flammable Liquid & Combustible Dusts Piping
Many may be familiar with “flange jumpers,” or some may call them “bonding jumpers,” that are used to ensure a continuity to ground across a flange with gaskets that act as “insulators”, such as PTFE gaskets. During a recent walkdown of a flammable liquids process, I came across this “jumper”. Design called for “jumpers” on each flange, and...
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EPA RMP/EPCRA citations @ Refinery (HF & $270K)
Respondent operated a facility (the “Facility”) that refines petroleum products using a hydrofluoric acid alkylation process. On June 2-3, 2022, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, EPCRA Sections 304-312, and CAA Section 112(r). Based upon the information gathered during...
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EPA RMP/EPCRA citations @ ethanol manufacturing facility (Flammables & $169K)
Respondent is the owner and operator of an ethanol manufacturing facility handling a mixture of hydrocarbon liquids, butane, isopentane, and pentane. Pursuant to 40 C.F.R. § 68.115(b)(2)(i), the entire weight of the mixture shall be treated as the regulated substance when the concentration of each of the regulated substances is 1% or greater by weight of the total concentration of the flammable mixture....
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EPA RMP/EPCRA citations @ food facility (NH3 & $262K)
Respondent operated a facility that utilizes anhydrous ammonia to provide cooling capabilities to package, refrigerate, store, and ship cherries and grapes.On September 16, 2021, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act Section 103, EPCRA Sections 304-312, and CAA Section 112(r). Based upon the information...
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What drives the need for Hydrostatic Relief Valves on piping?
Yes, I am still on this horse! As I discussed last month, there are a number of chemicals that specifically REQUIRE HRVs on liquid piping. Those are chemicals like NH3, Cl2, and LPG, to name the top three (3). But I have recently read a root cause analysis in which a flammable-liquid piping flange leaked, and it was attributed to “thermal expansion.” I called BS, and this is why…...
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Chemical hoses aren't the only hoses needing annual inspection and pressure testing!
I have written over a dozen posts explaining the code requirements for annual inspection/testing of our chemical hoses. But in the world of PSM/RMP, there is another hose that requires annual inspection and testing… The primary standard requiring fire hose to be service-tested annually is NFPA 1962, Standard for the Care, Use, Inspection, Service Testing, and Replacement of Fire Hose, Couplings,...
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Zero Energy State = 0
Another graphic depicting ZES = 0, not 0.1 psig
I have been having fun using AI to help me create training images. I love doing LOTO training, and I am always challenged on just how little energy it takes to be “hazardous” and how even 0.1 psig can be lethal. (as shown below) … HomeRead More »
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The math of a "Small" Vacuum
A couple of years ago, in a PHA, I came across a scenario where a “capture device” had quite “the pull” on several small tanks that were NOT rated for a vacuum. As usual, my inquiry was met with the old “this is the way all the other plants were built and they have not experienced any issues“. But I learned about the power of even a small vacuum the hard way in...
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EPA RMP image
How comprehensive does my RMP management system need to be? (EPA FAQ)
What is a management system (40 CFR §68.15(a))? How comprehensive must it be? Is there a standard format? … HomeRead More »
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NTSB Updates NaOH Truck Explosoin (5/8/26)
On April 7, 2026, about 7:15 a.m. local time, a DOT 407 AL (aluminum) cargo tank, owned and operated by Brenntag, carrying about 1,100 gallons of Sodium Hydroxide Solution (UN1824), exploded at a facility in Mooresville, North Carolina. The driver of the semi-tractor-trailer to which the cargo tank was attached was killed in the explosion. An employee of the facility suffered minor injuries due to...
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A FREE TOOL/Resource every safety pro should have in their toolbox - CGA Handbook of Compressed Gases
Did you know? The Compressed Gas Association’s Handbook of Compressed Gases is now available online — completely FREE and publicly accessible. Access it here:  https://handbook.cganet.com For decades, the Handbook has served as a trusted reference for professionals across the industrial, medical, food, beverage, specialty gas, and hydrogen sectors.  Now, CGA has transformed this essential...
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Line Break gone bad (H2S - pulling blind)
Shenyang Petrochemical Company “The Big Poisoning Accident“ The gas sub-device of Shenyang Paraffin Chemical Company suffered a poisoning accident during the maintenance and construction process, resulting in three (3) Deaths. The immediate causes of the accident were: When the operator carried out the blind plate swapping operation at the pump relief blind plate, the operator died due to inhalation...
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