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EPA RMP Citations @ a chemical manufacturing, warehouse, and distribution facility (NH3, CL2, GDC; $114K)
Safety Info Posts - PSM and RMP Citations/Analysis
Written by Bryan Haywood   
Monday, 29 September 2014 21:04

This CAFO resolves the following CAA violations that Complainant alleges occurred in conjunction with Respondent's storage and handling of hazardous substances at its facility:

  1. Failure to prepare and submit a Risk Management Plan that includes all covered processes, in violation of 40 C.F.R. §68.12(a) and 68.150(a);
  2. Failure to comply with process safety information requirements, including documentation of compliance with recognized and generally accepted good engineering practices, in violation of 40 C.F.R.§ 68.65 and/or 68.48; 
  3. Failure to comply with operating procedures requirements, in violation of 40 C.F.R. § 68.69; and 
  4. Failure to design and maintain a safe facility, in violation of the General Duty Clause, Section 112(r)(l) of the CAA, 42 U.S.C. § 7412(r)(1).
Last Updated on Monday, 29 September 2014 21:28
2014 Photo of the Week #39 (Emergency Response)
Safety Info Posts - Photo of the Week
Written by Bryan Haywood   
Saturday, 27 September 2014 00:00

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Last Updated on Saturday, 27 September 2014 15:03
2014 Video of the Week #39 (Ladder Accident & Hardhat)
Safety Info Posts - Video of the Week
Written by Bryan Haywood   
Saturday, 27 September 2014 00:00

57 incidents & 0 updates (9/25/14)
Safety Info Posts - Incident Alerts
Written by Bryan Haywood   
Thursday, 25 September 2014 21:13
STOP USE AND PRODUCT RECALL NOTICE - 3M™ Model SWSW Series Mobile SkyWalk Horizontal Lifeline Systems and Components
Safety Info Posts - Safety Alerts
Written by Bryan Haywood   
Thursday, 25 September 2014 14:49

A recent analysis of 3M™ Model Number SWSW Series Mobile SkyWalk horizontal lifeline systems identified that these systems may not satisfactorily meet the minimum requirements of OSHA 29 CFR 1910.66, 1926.502 regulations and may not arrest a fall in the working clearances stated in 3M user manuals. This system was previously sold under the name Aearo Series Mobile SkyWalk system or SafeWaze Series Mobile SkyWalk system.  3M has chosen to voluntarily recall the products impacted by this issue and requests that you immediately identify, stop use, and quarantine all Mobile SkyWalk horizontal lifeline systems.  CLICK HERE for the 9/12/14 announcement from 3M.

Last Updated on Thursday, 25 September 2014 14:55
Bench Testing your Relief Valves and IIAR
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Tuesday, 23 September 2014 14:40

As I have discussed many times with many clients, the practice of “bench testing” relief valves (RV) is a common practice in many industries; but in some industries the practice has been considered to be a waste of time and money. At least that was the case until now! It appears that one major trade group is taking a position that “bench testing” RV’s is not only a good safety practice, it is also GOOD BUSINESS. So maybe the days of hearing… “Bryan we are not a refinery… chemical plant… power plant… fertilizer plant… etc.” is behind us and we can move forward in improving process safety in the ammonia refrigeration industry. And yes I want to tip my hat and say THANKS to the International Institute of Ammonia Refrigeration (IIAR) for publishing “RVCalc, Using Weibull Analysis to predict valve replacement” this month (September 2014) in their “Condenser” magazine. We should not take this publishing lightly as it is a MAJOR step in the right direction and shows that IIAR is moving in the right direction. I can only imagine how this practice will be received by IIAR members, but without a doubt, it is a much needed change in this industry. To provide some contrast to how many are currently managing their RVs, consider this…

CAL OSHA's PROPOSED PSM Standard for Refineries
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Sunday, 21 September 2014 18:35

CAL-OSHA has issued a NPRM for a REVISED PSM Standard.  In addition to proposing changes to existing PSM language, the draft proposal introduces new requirements in the following areas: 

  • damage mechanism reviews
  • hierarchy of hazard controls analysis
  • human factors
  • management of organizational change
  • safeguard protection analysis
  • incident investigations
  • safety culture assessments

Here is the PSM Draft Regulation...

NOTE: the text that has been highlighted in BOLD RED represents the changes and differences in this PSM standard as compared to the existing CAL OSHA PSM standard AND the Federal PSM Standard.  Some VERY interesting proposed changes!

Last Updated on Sunday, 21 September 2014 21:32
Ammonia Explosion 30 years ago this week
Safety Info Posts - Hazardous Materials
Written by Bryan Haywood   
Friday, 19 September 2014 18:55

For many HAZMAT students, learning that a HAZMAT shipped as a Non-Flammable Class 2 HAZMAT can actually ignite is a sobering fact of emergency response. But when they find out this HAZMAT is anhydrous ammonia (NH3) there is a level of disbelief. But it was this week 30 years ago (9/17/84) at approximately 4:00 p.m., when an explosion occurred in a cold storage warehouse building near Shreveport, Louisiana. The explosion occurred while two members of the Shreveport Fire Department's Hazardous Material Unit were attempting to isolate an anhydrous ammonia leak in a section of the building's refrigeration system.

Last Updated on Friday, 19 September 2014 19:40
Safety Info Posts - Safety Alerts
Written by Bryan Haywood   
Friday, 19 September 2014 15:42

This Notice concerns the DBI-SALA Lad-Saf™ Flexible Cable Ladder Safety System, also known as a “Safety Climb System.” Capital Safety has received a limited number of reports of 7x19 strand carrier cable slippage from the carrier clamp in the top bracket of these ladder safety systems. Although this top bracket design has been used in the market for more than 40 years without incident, the reported slippage raises the potential for injury to users of affected systems. Based on our analysis of component manufacture dates, the affected systems are:  CLICK HERE for the official alert

Last Updated on Friday, 19 September 2014 15:45
EPA RMP Citations @ a dairy processing plant (NH3; $7,500)
Safety Info Posts - PSM and RMP Citations/Analysis
Written by Bryan Haywood   
Friday, 19 September 2014 13:22

On December 3, 2013, EPA conducted a compliance inspection of Respondent's facility to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.F.R. part 68 under section 112(r)(7) of the Act. The EPA found that the Respondent had violated regulations implementing section 112(r)(7) of the Act by failing to comply with the specific requirements outlined in the attached RMP Program Level 3 Process Checklist-Alleged Violations & Penalty Assessment (Checklist and Penalty Assessment). The Checklist and Penalty Assessment is incorporated into this ESA.

Last Updated on Friday, 19 September 2014 13:32

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