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EPA EPCRA citations @ Brewery (NH3 and $20K)
Safety Info Posts - Emergency Response
Written by Bryan Haywood   
Friday, 22 August 2014 10:21

The owner or operator of a Brewery, which uses anhydrous ammonia, as a refrigerant at the facility had a reportable release of ammonia on October 12, 2011 at or about 2:19 a.m.  Approximately 664 pounds of anhydrous ammonia spilled, leaked, pumped, emitted, discharged, or escaped into tbe ambient air and/or air from the facility.  Company had knowledge of the release on October 12, 2011 at approximately 2:19 a.m. Company knew or should have known immediately that the release was above the reportable quantity.  Facts that were cited:

Last Updated on Friday, 22 August 2014 10:27
DHS issues ANPRM for CFATS
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Friday, 22 August 2014 06:45

This ANPRM will provide an opportunity for the Department to hear and consider the views of regulated industry and other interested members of the public on their recommendations for CFATS program modifications and improvements.  Areas that DHS is most interested in receiving comments on include, but are not limited to, the following:

  1. General Regulatory Approach—Comments on how the Department could continue to improve its current approach toward identifying CFATS covered facilities and ensuring their compliance with CFATS requirements, such as:
    1. the information submission processes (i.e., the Top-Screen, SVA, and SSP submissions) and associated schedules; [11]
    2. the means and methods by which facilities claim a statutorily exempt status and whether or not commenters think that deletions, additions or modification to the list of exempt facilities should be considered;
    3. the use of ASPs in lieu of SVAs and, in particular, the current limitation on the use of ASPs in lieu of SVAs to Tier 4 facilities;
    4. the, scope, tier applicability and processes for submitting and reviewing SSPs and ASPs;
    5. the processes for submitting and evaluating requests for redetermination by chemical facilities previously determined by DHS to be high-risk; and
    6. the issuance of orders and the regulatory enforcement process.


Last Updated on Friday, 22 August 2014 06:56
EPA RMP Citations @ a Refinery ($120K )
Safety Info Posts - PSM and RMP Citations/Analysis
Written by Bryan Haywood   
Thursday, 21 August 2014 20:05

Count 1. Violation of 40 C.F.R. § 68.69(c)

40 C.P.R.§ 68.69(c) requires, in relevant part, that owners and operators must annually certify that operating procedures are current and accurate.

Respondent requires that operating procedures certifications are complete by May 26 of each calendar year. Respondent failed to certify procedures by this deadline for two processes in 2009. Through its failure to annually certify that operating procedures were current and accurate, Respondent violated 40 C.F.R. § 68.69(c).

Process Safety and calibrated direct-reading instrument
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Thursday, 21 August 2014 13:56

On the most basic level, can a PSM/RMP program function and comply with all regulatory requirements and NOT have a calibrated direct-reading instrument?

This is not meant to be a trick question, but rather looking to "ground me" in my expectations.  Having grown up in the PSM/RMP era in petrochem for 20 years, having a calibrated direct-reading instrument available was like having my hardhat and safety glasses available.  I do not think a day went by where I did not personally rely on a portable gas detector.  In fact, several of my plants we were REQUIRED to wear a detector at all times while signed into the unit.  But the $64M question is...

Last Updated on Thursday, 21 August 2014 14:04
2013 HAZMAT Loading/Unloading Incidents
Safety Info Posts - Hazardous Materials
Written by Bryan Haywood   
Wednesday, 20 August 2014 20:40

U.S. Department of Transportation
Pipeline and Hazardous Materials Safety Administration
Office of Hazardous Material Safety
2013 (All Column Values) Hazmat Summary by Transportation Phase

Screen Shot 2014-08-20 at 9.43.23 PM

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CLICK HERECLICK HERE to work with the database

Last Updated on Wednesday, 20 August 2014 20:48
10 years of NH3 and CL2 release data (2004-2014)
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Wednesday, 20 August 2014 13:11

Last week I shared an article from that provided some data on Ammonia releases.  The article was not well received by some folks and others appreciated the info, which is par for the course when you post this kind of material.  But some have gone off the deep-end and called the article "spin" and "propoganda" against ammonia.  For the record, the article's data was NOT 100% factual, but as it turns out it was actually MORE FAVORABLE to ammonia than what my data analysis shows.  The article appears to have used other sources, but I used the following sources for my data:

  • Hazardous Substances Emergency Events Surveillance (HSEES)
  • National Toxic Substance Incidents Program (NTSIP)
  • United States Coast Guard National Response Center
  • The Right-to-Know Network, RMP Data Base

This posting is to provide factual numbers for the two most widely used PSM/RMP chemicals (NH3 and CL2) and compare uncontrolled releases from their primary containment.

Last Updated on Wednesday, 20 August 2014 20:38
54 incidents & 4 updates (8/17/14)
Safety Info Posts - Incident Alerts
Written by Bryan Haywood   
Sunday, 17 August 2014 20:50
Last Updated on Sunday, 17 August 2014 20:54
OSHRC decision on PSM Contractor Training and Work Permits
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Saturday, 16 August 2014 19:31

The host facility, an anhydrous ammonia storage facility,  contracted with a company, who in turn, contracted with Respondent (sub-contractor) to perform services on pipelines within the facility. Respondent provides sixteen different services or “lines”, as it refers to them. Each of these lines is comprised of crew members that have been trained and tested in that particular discipline. Some of the crew members are trained in multiple lines, and, based on their respective amount of experience, may be designated as a crew lead. One of these lines involves the installation of isolation plugs (also referred to as mechanical plugs) into pipelines. These plugs serve as a barrier between flammable gases in the pipelines and hot work, such as welding. The plug has a series of bolts that are tightened in order to expand a two-part rubber seal that presses outward against the pipe. Once the rings are expanded, the plug is filled with water and pressurized by bleeding off the air within the plug. A through-port is installed and connected to a hose, which is placed in a bucket of water approximately 35 to 50 feet away. The purpose of the hose and bucket is to detect the accumulation of pressure behind the plug, which results from hydrocarbons being released from the pipe due to the presence of heat. If there is pressure build-up, the hot work is supposed to be stopped by the individual monitoring the plug and will not recommence until the pressure is reduced. The plug also has a gauge that measures the pressure of the water in between the rubber seals. As was the case here, improper installation and/or handling of the plug can result in serious injuries.

Last Updated on Saturday, 16 August 2014 19:40
Safety Bulletin - Entry of a confined space on board a cargo ship resulting in three fatalities (Marine Accident Investigation Branch (MAIB)
Safety Info Posts - Permit Required Confined Spaces
Written by Bryan Haywood   
Saturday, 16 August 2014 14:15

At approximately 0645 (UTC+1) on 26 May 2014, three crew members on board a cargo ship were found unconscious in the main cargo hold forward access compartment, which was sited in the vessel’s forecastle. The crew members were recovered from the compartment but, despite intensive resuscitation efforts by their rescuers, they did not survive.

Last Updated on Saturday, 16 August 2014 14:24
EPA RMP Citations @ agricultural chemical manufacturing facility (NH3 and aqueous ammonia; $101K) )
Safety Info Posts - PSM and RMP Citations/Analysis
Written by Bryan Haywood   
Saturday, 16 August 2014 13:29

Respondent owns and operates an agricultural chemical manufacturing facility. Respondent has been subject to the RMP requirements since June 21, 1999, as provided in 40 C.F.R. § 68.1O(a)(1), because the facility used, stored, manufactured, or handled more than the TQ of 10,000 pounds of anhydrous ammonia in a single process as of that date. Respondent became subject to the RMP requirements for aqueous ammonia on July 1, 2010, the date on which the facility first used, stored, manufactured, or bandied more than the TQ of20,000 pounds of aqueous ammonia in a single process.

Last Updated on Saturday, 16 August 2014 13:35

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