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Soladigm since 2011, ZION Solutions since 2008, AMG Vanadium since 2008, Abbott since 2008

In this week’s Newsletter


  •  A breakdown of the NFPA 30 -2012 changes

  •  More OSHA PSM Citations on a NH3 Refrigeration Process (includes NO MOC on personnel changes!)

  •  OSHA has not granted a waiver from compliance due to short supply of FRC

  •  New guidance document helps construction employers and workers prevent nail gun injuries

  •  Electrical FAQs

  •  Prevention through Design Standard

Side Bar Items:

  •  SAFTENG Blog & SAFTENG LinkedIn Forum
  •  Safety and Health Tip – Another video that EVERY WORKER should see! 
  •  Civilian Fire Fatalities
  •  Safety Recalls
  •  EHS Events

A breakdown of the NFPA 30 -2012 changes

NFPA has released the 2012 edition of NFPA 30 - Flammable and Combustible Liquids Code.  There are some changes in this new 2012 edition.  They are intended to respond to newly identified risks:

1. New provision requires that Class II and Class III liquids stored, handled, processed, or used at temperatures at or above their flash points follow all applicable requirements in the Code for Class I liquids, unless an engineering evaluation deems otherwise.
2. An annex item explains that the use of spark-resistant tools must be evaluated on a case-by-case basis.
3. In response to U.S. DHS rules requiring security/vulnerability assessments for high-hazard facilities, new Section 6.10 and an accompanying Annex H have been added to address management of facility security by means of a mandatory security and vulnerability assessment. Annex G provides an outline of a suggested assessment process.
4. New annex guidance covers selecting a safe location to which a flammable liquids storage cabinet may be vented, and selecting a safe location to which a flammable liquids dispensing area may be vented.
5. Provisions for flammable liquids storage cabinets incorporate more extensive marking requirements.
6. Revised Table 9.9.1, Fire Resistance Ratings for Liquid Storage Areas, indicates that no fire resistance rating is required for separation walls for accessory use areas of small floor area.
7. Revised Section 13.3 more clearly establishes the required separation between detached unprotected liquids storage buildings and both protected and unprotected exposed properties.
8. Numerous minor amendments have been made to clarify application of the provisions of Chapter 16, Automatic Fire Protection for Inside Liquid Storage Areas.
9. New Subsection 17.3.7 has been added to address process vessels used to heat liquids to temperatures at or above their flash points, as suggested by investigations conducted by the U. S. Chemical Safety and Hazard Investigation Board.

10. New provision clarifies that tightness testing is not required for an interstitial space of a secondary containment tank that maintains factory-applied vacuum.
11. A note and annex item for Table, Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks, explain the term "sum of adjacent diameters" and its determination.
12. Changes provide additional guidance on handling floating roof pontoons that have been breached by liquids or vapors.
13. The Code no longer allows the use of water ballast to secure underground tanks in areas subject to flooding.
14. Use and installation of alcohol-based hand rub dispensers are now exempted from the Code.
15. Revised definitions for the various types of building occupancies correlate NFPA 101®: Life Safety Code®.

For a detailed breakdown and the new/revised code language, Click Here.


More OSHA PSM Citations on a NH3 Refrigeration Process (includes NO MOC on personnel changes!)  

No mention if this inspection was an NEP, scheduled, or complaint; but 9 of 12 citations were PSM.  They include:

1) The employer did not develop P&IDs which accurately represent current equipment for the ammonia refrigeration system.

2) No periodic inspections of the energy control procedures at least annually.

3) The employer did not train affected employees prior to the start-up of the plate and frame heat exchanger.

4) The employer did not implement written procedures during the installation of a back pressure control valve on a flange-bolt assembly.

5) The employer failed to inspect and test emergency shutdown systems and controls per the applicable manufacturer's recommendations and RAGAGEP(s). Specifically a) Ammonia sensors were not calibrated per the manufacturer's recommendations. b) The emergency ventilation system for Engine Room #2 was not tested per recognized and generally accepted good engineering practices. c) The emergency ventilation system for the CLSP Booster Compressor Room was not tested per RAGAGEP(s).

6) The employer did not correct deficiencies in equipment that were outside acceptable limits before further use or in a safe and timely manner (2 PSVs were past their inspection/test or replacement dates).

7) The employer did not update the piping and instrument diagrams (P&IDs) when the installation of Air Make-up Unit (AMU) 118 was installed which resulted in a change in the process safety information.

8) The employer did not develop an energy control procedure that clearly and specifically outline the steps for locking out or tagging out machines to control hazardous energy.

9) The employer did not implement procedures to manage changes to the management personnel prior to the change. Specifically a) Changes to the Facility Manager, b) Changes to the Powerhouse Supervisor, c) Changes to the PSM Coordinator)


Click Here for the actual citations. 


OSHA has not granted a waiver from compliance due to short supply of FRC

If employers are experiencing difficulty acquiring the necessary FRC due to issues such as order backlogs or extended delivery dates, OSHA will work with employees to resolve compliance issues related to these situations. To resolve these type situations, OSHA expects employers will:

1) have contacted their suppliers and placed orders for FRC;

2) be able to demonstrate that the FRC are on back order or are in the process of being delivered; and

3) when requested, provide the Agency with evidence of the date when FRC are to be delivered and

4) provide and use appropriate interim measures to protect workers.

Click Here to see the entire LOI.

New guidance document helps construction employers and workers prevent nail gun injuries

OSHA and NIOSH have developed new guidance, Nail Gun Safety – A Guide for Construction Contractors, to help construction employers and workers prevent work-related nail gun injuries.  Construction workers, particularly those in residential construction, use nail guns nearly every day. Although this tool is easy to operate and increases productivity, there have been reports of internal and external bodily injuries. These injuries occur as a result of unintended nail discharge; nails that bounce off a hard surface or miss the work piece and become airborne; and disabling the gun’s safety features, among other causes. Injury prevention is possible if contractors take steps such as using full sequential trigger nail guns; establishing nail gun work procedures; and providing workers with personal protective equipment.  Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit  NIOSH is the federal agency that conducts research and makes recommendations for preventing work-related injuries, illnesses, and deaths.  More information can be found at

Electrical FAQs

The UK's Health and Safety Executive (HSE) has put out an EXCELLENT tool to help educate workers on the hazards of electricity and the safety practices for working safely around electricity.  The Frequently Asked Questions are:

  1. Which is safer; alternating current (AC) or direct current (DC)?
  2. Everyone gets a 'belt' from electricity every now and then, don't they?
  3. How do I know if my electrical equipment is safe?
  4. How do I know if my electrical installation is safe?
  5. Who should I talk to about electrical safety?
  6. What voltages are dangerous?
  7. What should I do if I think I have seen an unsafe electrical installation or equipment?
  8. How do I know if someone is competent to do electrical work? 
  9. Can I do my own electrical work? 
  10. When should I use a residual current device? 
  11. When should I report an electrical accident to HSE? 
  12. What should I do if I think someone is working unsafely? 
  13. What should I do to avoid danger from underground cables or wires? 
  14. How do I work safely near overhead lines? 
  15. What should I do if I touch an overhead power line? 
  16. When is it safe to work on live electrical equipment? 
  17. How do I make my electrical equipment safe to work on? 
  18. Who has the responsibility to make sure everyone works safely? 
  19. I may have a color vision deficiency which could affect my ability to do electrical work. Is there any guidance available? 
  20. There may be asbestos in or near the equipment I am working on. Is there any guidance available? 
  21.  How often should I test my electrical equipment?
  22. How often should I get my electrical installation tested? 

Prevention through Design Standard

The American Society of Safety Engineers (ASSE) recently announced the approval of the American National Standards Institute (ANSI)/ASSE standard, "Prevention through Design: Guidelines for Addressing Occupational Risks in Design and Redesign Processes" (Z590.3). This new standard provides guidance on including Prevention through Design concepts within an occupational safety and health management system, and can be applied in any occupational setting.  The new standard focuses specifically on the avoidance, elimination, reduction and control of occupational safety and health hazards and risks in the design and redesign process. Through the application of the concepts presented in the standard, decisions about occupational hazards and risks can be incorporated into the process of design and redesign of work areas, tools, equipment, machinery, substances and work processes. Design and redesign also includes construction, manufacture, use, maintenance, and disposal or reuse of equipment used on-the-job. One of the key elements of this standard is that it provides guidance for "life-cycle" assessments and a design model that balances environmental and occupational safety and health goals over the life span of a facility, process or product. The standard focuses on the four key stages of occupational risk management. The pre-operational, operational, post incident and post-operational stages are all addressed within.  This standard can save lives and prevent injury. For example, as skylights become synonymous with green construction and energy conservation, we expect to see an increase in skylight installation. If skylights are designed and installed with proper guarding, deaths and injuries to workers who inadvertently fall though skylights during construction and maintenance activities could be prevented. Another example involves bailing machines used to break down cardboard for recycling in various industries. If the bailers were designed and installed with proper guarding, workers would not be able to enter the machines for trouble shooting thus preventing deaths and injuries.  Development and publication of this standard was a major goal for the NIOSH Prevention through Design Plan for the National Initiative. ASSE's leadership in developing this standard and gaining ANSI approval lays the foundation for organizations to include Prevention through Design principles in their occupational safety and health management systems. The standard also provides tools for determining and achieving acceptable levels of risk to hazards that cannot be eliminated during design.  The new standard complements, but does not replace, performance objectives existing in other specific standards and procedures. The goals of applying Prevention through Design concepts in an occupational setting are to:

  •  achieve acceptable risk level;
  •  prevent or reduce occupationally related injuries, illnesses, and fatalities; and
  •  reduce the cost of retrofitting necessary to mitigate hazards and risks that were not sufficiently addressed in the design or redesign processes

The newly approved standard will be available soon in print and electronically. For more information, please contact ASSE Customer Service at 847-699-2929 or This email address is being protected from spambots. You need JavaScript enabled to view it..">This email address is being protected from spambots. You need JavaScript enabled to view it.. 

MEMBERSHIP SPECIAL:  Due to our Corporate Support this year and because so many safety professionals have fallen on hard times, I have decided to extend the special NEW Membership fee of $30 for everyone.  Of course anyone can join for FREE by becoming a “contributor of materials” for me to posts.  Just use the “Renewal Option” and send me an e-mail letting me know you are a NEW MEMBER and I will set you up within 24 hours.



SAFTENG LinkedIn Forum

Click Here to Join the Safety Engineering Network (SAFTENG) Forum on LinkedIn forum.  It's FREE! We now have 1,373 members

NOTE:  If you and I are not "Linked" send me an invitation and I will accept.  I accept ALL invitations from safety professionals.  Also, if you use LinkedIn PLEASE consider joining the Safety Engineering Network LinkedIn Forum.

Discussions @ Safety Engineering Network LinkedIn Group:

  • Free Safety Apps for Smart Phones
  • NFPA 30: Flammable and Combustible Liquids Code, 2012 Edition
  • OSHA, LOTO and the unexpected movement of trucks - Safety Engineering Network (SAFTENG)
  • OSHA SHARP Program - Is it effective? Data suggest VERY MUCH SO!
  • PSM Battery Limits - it may not be as simple as "Interconnected"
  • More OSHA PSM Citations on a NH3 Refrigeration Process (includes NO MOC on personnel changes!)
  • OSHA PSM LOI - Determining when a mixture would exceed the threshold quantity in a covered process
  • OSHA has not granted a waiver from compliance due to short supply of FRC!
  • 21 incidents & 2 updates (9/26/11)
  • Alabama's ABC Coke cited for 27 safety and health violations by OSHA following worker fatality
  • Need to understand more about ISO 13849-1?
  • Photo of the Week - Confined Space Shocker
  • State Fire Marshal Concludes Investigation into Bostik Explosion
  • What is the difference between "street glasses" and ANSI High Impact Safety Glasses
  • Electrical FAQs - Electrical safety at work
  • New post digging into ISO 13849-1 Category 3
  • OSHA cites a Brewery $108,000 for exposing workers to ammonia, other hazards (PSM)
  • Investigation Found Lack of Safe Equipment Design, Ineffective Mechanical Integrity Programs, and Failure to Investigate Near Misses
  • 31 Incidents & 0 Updates (9/22/11)
  • United States Chemical Safety Board "CSB"
  • OSHA cites ice cream manufacturer for PSM and LOTO

Jobs posted on SAFTENG LinkedIn Forum:

  • Currently looking for Senior & Principal level Safety & Risk Engineers for the North West of England
  • SAFETY OFFICER for a work project in Olkiluoto Finland for an interesting long term
  • Senior Safety Engineer (Defence) job in South East - Salary: £55000 - £65000 per annum + Excellent Benefits package

Safety and Health Tip

Another video that EVERY WORKER should see!

Although I must warn you, this video contains some harsh language and graphic images - IT IS TRUE TO LIFE AND DEATH!  Very HIGH IMPACT for just three minutes.  Many thanks to Stephen Harris for sharing.  Click Here to see the video.


Civilian Fire Fatalities

On September 27, 2011, 2 residential fire fatalities were reported by news media throughout the United States.

Safety Recalls

Bridgeway Recalls Bicycles Due to Fall Hazard

Specialized Bicycle Components Recalls Bicycles Due to Fall Hazard

American Woodcrafters Recalls to Repair Bunk Beds Due To Fall Hazard


Vehicles Recalls

Tires Recalls

Child Safety Seat Recalls


EHS Events

Mary Kay O'Connor Process Safety Center International Symposium

October 25-27, 2011

College Station, TX

If you have a conference or an outing for your safety organization, let me now and I can help spread the message.  And yes, posting is FREE!

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Wednesday 6/10 @ 7:45 a.m.

Process Safety Management

Enforcement Trends and Best Practices

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