OSHA has cited a power plant and it's security services provider, for $43,458 in total proposed penalties, following a release of anhydrous ammonia at its Gibsonton facility.  On May 23, 2017, OSHA responded to the incident and determined that the ammonia release occurred when a relief valve activated after a pipeline became over pressurized. As a result, four workers were taken to the hospital for observation and released.  OSHA issued the power plant two serious citations for failing to include all the minimum requirements in their emergency response plan and not ensuring employees exposed to hazardous substances wore appropriate respiratory protection. The Agency also issued the power company a Hazard Alert Letter with recommendations to mitigate asphyxiation hazards.  The investigation also led to citations for the security services provider, which received two serious violations for not developing or implementing a written hazard communication program, and failing to provide information and training on hazardous chemicals in the workplace.  Here are the citations:

NOTE: this is the same power plant that had the fatal slag tank accident earlier in the year.

There has been a lot of discussions these past several years about having an "in-house emergency response team" vs. relying on "external response services" (e.g. local FD or contracted services on a case-by-case basis).  There is NO one right or wrong answer and each facility and its hazards and needs are all quite different.  This week OSHA published a Fact Sheet titled Evaluation of Fire and Rescue Services (#3925).  The fact sheet was published SPECIFICALLY for Shipyards; however, after reviewing it, there is a lot of great information in it that can be applied to other industries.  If your PSM/RMP facility or you have personnel who enter Permit-Required Confined Spaces (PRCS) using the "entry permit" method for entry then this Fact Sheet may be helpful in your evaluation of your fire and rescue services.  And remember, sometimes the OSHA standards specific to a different industry may be better than what our actual industry standard requires. For example, did you know that OSHA's PRCS standard for Shipyards limits the upper Oxygen limit to 22%, not the 23.5% allowed in General Industry or that OSHA prohibits entry into ship spaces when the LEL is at 10% or higher, whereas the general industry standard permits entry in a space with a LEL >10%.  SAFTENG members can see my comparisons in the Permit-Required Confined Space Section.

  1. How many chemicals have an assigned IDLH level?

  2. FEMA releases the refreshed National Incident Management System (NIMS)

  3. Off-Site/Open Enrollment Emergency Response Courses and their limitations

  4. BFD Ammonia Fatality Radio Traffic w/ timeline

  5. Interesting response to leaking NH3 Tank Truck (Outside of USA)

  6. PHMSA's New Cylinder "Special Permit" authorizes an extension of the 15-year service life of certain carbon fiber reinforced aluminum-lined cylinders (DOT-CFFC)

  7. Difference between Emergency Planning in a Public Fire Department and Private Response Group

  8. Where Did “Shelter-in-Place” Come From?

  9. Do the actions taken under PSM duties/SOPs exempt the facility from the scope of HAZWOPER?

  10. Mobile app version of CAMEO Chemicals is now available for both iOS and Android devices

  11. How to Use the 2016 Emergency Response Guidebook (ERG) Pipeline and Hazardous Materials Safety Administration (Video)

  12. New versions of CAMEOfm and Tier2 Submit are now available (December 2016)

  13. Congress passes RESPONSE Act of 2016

  14. NIOSH Updates to Immediately Dangerous to Life or Health (IDLH) Value Profiles

  15. ALOHA® - Guidebook with Example Scenarios (September 2016)

  16. New versions of ALOHA and CAMEO Chemicals are now available (September 2016)

  17. OSHA HAZWOPER citations @ coffee manufacturing facility (CO2 & $63K)

  18. NEW version of CAMEO is now available (May 2016) 2016 Emergency Response Guide (ERG) now available

  19. Why Off-Loading HAZMAT before moving container is critical
  20. Boston NH3 fatality and BFD response brings us back to the ER PPE discussion for NH3
  21. New versions of ALOHA and CAMEO Chemicals available
  22. Attempt at burning derailment vapor goes WRONG!
  23. PPE saves two lives (Video)
  24. NEW 2016 EMERGENCY RESPONSE GUIDEBOOK
  25. New versions of CAMEOfm and Tier2 Submit
  26. MARPLOT 5.0.3 is now available for download
  27. Atmospheric Storage Tank fails under fire conditions (caught on helmet cam)
  28. MARPLOT 5.0.2 is now available for download
  29. CDC/NIOSH just answered the question... is LEVEL A needed for a NH3 release?
  30. New releases of WISER are available for every current platform
  31. Fire Protection Deficiencies to incorporate into our inspection programs and internal audit programs
  32. Today marks the 1-year Anniversary of "The Back Bay Blaze" where UNSAFE Hot Work Practices claimed the lives of two Boston FF's
  33. MARPLOT 5.0.1 is now available for download
  34. MARPLOT 5.0 Available for Windows and Mac
  35. Controlled vent and burn of product in derailed tank cars in Gainford, Alberta
  36. Crude By Rail Emergency Response 4-Hour Web-based Training
  37. So does the state of Ohio require an annual fire drill?
  38. Means of Egress: Handrails (USFA)
  39. Incidental Release or Uncontrolled Release of NH3 - What say you?
  40. HAZWOPER Question... Does a person who will ONLY participate in Decon be required to have Operations or Tech level training?
  41. OSHA HAZWOPER Citations @ manufacturer of plastic thermoformed products (HAZWOPER, PPE & HAZCOM; $49K)
  42. OSHA's First Aid and BBP training requirements
  43. Minor update versions of MARPLOT and CAMEOfm are now available
  44. Airline Respirator Hose Storage (firefighter fell unconscious)
  45. New Versions of CAMEOfm and Tier2 Submit are available
  46. Fire Dynamics: The A, B, C, D and K’s of Fire (USFA)
  47. WISER for iOS 3.1.1 Released & Important Ebola Resources
  48. How NOT to manage a Propane Release scene! (Video)
  49. Portable Extinguishers: Monthly Inspections (USFA)
  50. Drawing the line between “Operators” and “Emergency Responders”
  51. Knowing the limitations of your emergency response equipment
  52. SCBA Cylinder Retester Locations (PHMSA)
  53. Three Firefighters Injured While Recharging A Pressurized Water Fire Extinguisher
  54. EPA EPCRA citations @ Brewery (NH3 and $20K)
  55. Can FF Turn-Out Gear be repaired with "used" materials from other gear (NFPA Interp)
  56. NFPA BLEVE Training Video (Full 20 Minutes)
  57. UNPREPARED Emergency Escape Breath Devices (EEBD)/Emergency Life Support Apparatus (ELSA) (USCG)
  58. Storage Practices: Controlled Atmosphere Storage (USFA)
  59. SAFER Systems Unveils Free Chemical Emergency Response Smartphone App. With Real-Time Weather and Traffic Data
  60. OSHA Notice of stakeholder meeting - Emergency Response
  61. NOW this is DRILLING/TRAINING
  62. Why is 1910.120(q)(3)(iv) such a mystery?
  63. Fire Brigades paper work requirements
  64. Do you have good breathing air?
  65. Understanding Emergency and Standby Power Levels (USFA/NFPA)
  66. U.S. DOT Takes New Emergency Actions as Part of Comprehensive Strategy to Keep Crude Oil Shipments Safe
  67. BLEVE Training Video from Transport Canada
  68. BLEVE Training video from 1970's (Amazing footage)
  69. Explaining the mechanics of a BLEVE (NFPA)
  70. Drone fly-over at VA train derailment (Video)
  71. OSHA fines manufacturer of electrical power delivery products after multiple workers injured by acid mixture (HAZWOPER and $166,000)
  72. New Emergency Kit "C" Instructional Video Now Available (Video)
  73. Are you maintaining your LEVEL A suits "by the book"?
  74. Scott Safety Announces the Scott Extended Life 30-Year Cylinder
  75. Newly Released B-Kit (Ton Cylinder) and C-Kit (Chlorine Tank Cars & Tank Trucks) Now Available and FREE Download
  76. OSHA's emergency response expectations in 1910.120
  77. Electronic Incident Command System (ICS) Forms from USCG and NOAA
  78. Take a walk with Firefighters investigating a 4,000 pound NH3 release (Video)
  79. The difference in DECON
  80. EPCRA Reporting of Releases
  81. LEARNING from Training Errors - Live Fire Drill spayed jet fuel onto prop instead of water
  82. Evaluation and Acceptance of Emergency Breathing Support Systems (EBSS) Incorporated into SCBA Approvals
  83. (UPDATED on 3/10/14) Friendly Tier II reminder for Ohio facilities (FD/LEPC Approval Signature)
  84. Fatal Foam System Discharge
  85. WebWISER 4.5 is now available
  86. MSHA has updated the coal mine rescue team certification criteria
  87. Are Ohio Fire Departments required to have a Respiratory Protection Program?
  88. Ohio Firefighters and Safety Standards
  89. Characteristics of the Incident Command System: Part 5 (USFA)
  90. New versions of CAMEOfm and Tier2 Submit are now available
  91. Characteristics of the Incident Command System: Part 4 (USFA)
  92. WISER for Windows 4.5 is now available
  93. A new version of MARPLOT is available (4.2.4)
  94. NIOSH Updates Methodology for establishing IDLH Values
  95. OSHA's Frequently Asked Questions on HAZWOPER (1910.120)
  96. Characteristics of the Incident Command System: Part 3 (USFA)
  97. Buyer Beware! Don’t Be Fooled by Online-Only CPR or First Aid Certification Scams
  98. Characteristics of the Incident Command System: Part 2 (USFA)
  99. Characteristics of the Incident Command System: Part 1 (USFA)
  100. How NOT to handle an emergency (NOX release over major highway) Video
  101. NH3 Suppression Tarp - HIGHLY EFFECTIVE (video)
  102. Liquefied Natural Gas Safety and Emergency Response Video (PHMSA)
  103. Fire Pumps: Cavitation (USFA)
  104. New versions of ALOHA and CAMEO Chemicals are now available
  105. PART II - Scene Management is a function of IC (20 Ton NH3 Release)
  106. Standpipe Systems: Standpipe Hose Connection Clearance (USFA)
  107. Baltimore Derailment crossing Impact and Explosion (Video - 5/2013)
  108. National Academies Press Releases New Volume of AEGLs Publication
  109. Employers CHOICES differ between EPA and OSHA with Emergency Response decisions
  110. Infamous video of FF blown off Ladder Truck in Pasadena, TX
  111. Scene Management is a function of IC
  112. FREE Emergency HAZMAT Planning Guide
  113. The lost art of preplanning and the role of the Local Emergency Planning Committee (LEPC)
  114. West, TX Explosion and Community Emergency Response Plan?
  115. HIGH CHALLENGE Warehousing: Ammonium Nitrate as a typical case study (NFPA)
  116. Sprinkler System's OS&Y Valves
  117. Chlorine and Mouthpiece Emergency Escape Respirators
  118. A new version of MARPLOT is available (4.2.3)
  119. Modified Emergency Kit “C” Application for Certain Dual Valve Systems
  120. EPA publishes "Area Contingency Planning Handbook"
  121. UPDATE to the "Ammonia behaving badly... it is suppose to rise!" (Video)
  122. The Role of Scene Assessment or Size-up (USFA)
  123. CAMEO Chemicals 2.4 is now available
  124. What training is REQUIRED for "Incident Commanders"?
  125. FDA looking to REQUIRE AED approvals
  126. WISER for iOS 3.1
  127. “Getting Ready for the Unimagined:” Looking at the Emergency Operations Plan (USFA)
  128. Emergency Egress and Fire Doors
  129. Fire Extinguishers... Did you know they have to be identified?
  130. A rescue caught on tape, FF's rescue 4-year old from 2nd floor
  131. FREE "Incident Safety Officer (ISO)" Training videos (4 Parts)
  132. FREE NFPA Guide to Understanding & Implementing NFPA 1500, 1720, and 1851
  133. How long does a 4500 psi SCBA cylinder really last
  134. Respirators and Emergency Working Conditions
  135. Incident Commander Characteristics (USFA)
  136. Emergency SCBAs and OSHA requirements
  137. Key Changes to NFPA 1981/1982 SCBA Requirements
  138. The Incident Commander (from USFA)
  139. SCBA's and LOW TEMPERATURE use and storage
  140. FREE Emergency Response Guidebook (ERG) Training
  141. Mandatory elements of a HAZWOPER baseline physical examination
  142. CHLOREP Informational Bulletin: 2012 DOT/TC Emergency Response Guidebook
  143. Ray O'Brocki, of the Baltimore Fire Department, explains how night clubs and other high-capacity facilities deal with fire safety
  144. 2012 DOT ERG Training Video (21 Minutes)
  145. What you need to know about nightclub safety (NFPA Video)
  146. The FULL and UNEDITED Station Nightclub Fire Video (from within)
  147. BLEVE in the back of pickup at drive thru (Video)
  148. A VERY POWERFUL FIRE SAFETY message (Station Nightclub Survivor)
  149. Vent and Burn Training Video from Transport Canada
  150. Inspection Techniques: Egress Door Hardware Considerations
  151. Chlorine Leak video footage (17K pound 2002 Festus, MO)
  152. CI C-Kit Training Video
  153. On "oldie" but a goodie... Original CI C-Kit Video
  154. New versions of CAMEO 2.4 and Tier2 Submit
  155. Pipeline Safety: Communication During Emergency Situations
  156. Just The Facts...About The C-Kit (From CI)
  157. Shelter-in-Place Suggestions
  158. Cracking and Ruptures of SCBA Aluminum Cylinders Made from 6351 Alloy
  159. Safety Advisory; High Pressure Aluminum Seamless and Aluminum Composite Hoop-Wrapped Cylinders
  160. USFA Special Report: Prevention of Self-Contained Breathing Apparatus Failures
  161. 2012 DOT ERG by the numbers
  162. SCBA Cylinder Catastrophic Failure from Stress Corrosion Cracking
  163. Hydro-Testing of SCBA Cylinders
  164. CAMEO Chemicals mobile site now available
  165. The new "Table 3" in the 2012 DOT ERG
  166. Chemical facility faces ammonia leak penalty
  167. CHLOREP Informational Bulletin: 2012 DOT/TC Emergency Response Guidebook
  168. UL warns of counterfeit UL Mark on single-jacketed fire hose
  169. A "vent and burn" operation on I-10 in LA
  170. NEW version of CAMEO Chemicals is now available
  171. Emergency Response Equipment Maintenance
  172. Mandatory elements of a HAZWOPER baseline physical examination (OSHA LOI issued 7/2012)
  173. Columbus, OH Derailment Fire
  174. WISER for iOS 3.0 - Now Available in the Apple App Store
  175. Open-Circuit Self-Contained Breathing Apparatus Remaining Service-Life Indicator Performance Requirements
  176. Threshold Planning Quantities for EHS revised
  177. Introduction to the 2012 DOT Emergency Response Guide Book from PHMSA (Video)
  178. 2012 DOT Emergency Response Guidebook available for download
  179. Emergency Response Guidebook 2012 Summary of Changes (April 2012)
  180. The future of fixed fire protection????
  181. What's wrong with this scene?
  182. Who falls into OSHA’s HAZWOPER “Awareness” group?
  183. Volunteer Emergency Responders - who enforces their safety?
  184. Emergency Response Resources Side-by-Side Comparison
  185. PHOSGENE Emergency Response Data (insert for ERP)
  186. METHANOL Emergency Response Data (insert for ERP)
  187. HYDROFLUORIC ACID (HF) Emergency Response Data (insert for ERP)
  188. CHLORINE Emergency Response Data (insert for ERP)
  189. Ammonia Emergency Response Data (insert for ERP)
  190. Ammonia Exposure – Pre-hospital Medical Management
  191. Sample Protocol for a Response Plan (General Outline)
  192. What are Public Exposure Guidelines?
  193. What are Protective Action Criteria for Chemicals (PACs)?
  194. What are Temporary Emergency Exposure Limits (TEELs)?
  195. What are Acute Exposure Guideline Levels (AEGLs)?
  196. What are Emergency Response Planning Guidelines (ERPGs)?
  197. My podcast with Garden City Ammonia Program on ER
  198. Breaking down 1910.120(q)(2) Written ERP requirements
  199. Analysis of an ammonia spill and response
  200. Medical Fact Sheet for Ammonia
  201. How to use the DOT Emergency Response Guide Book (video)
  202. "Shelter-in-Place" may not be as EASY as it sounds
  203. Understanding OSHA's HAZWOPER standard for Emergency Response
  204. HAZMAT Team members MUST have an EXIT PHYSICAL
  205. New versions of ALOHA and CAMEO Chemicals are now available (3/22/12)
  206. The OLD and NEW IDLH and a little history about the MOST important term for any HAZMAT Technician
  207. Next Generation Breathing Apparatus A MUST SEE if you use SCBA's
  208. NUCOS: Unit Converter for Spill Responders
  209. FREE Training Resources for Responding to Ethanol Incidents
  210. Emergency Planning and Preparedness (CSB Video)
  211. Emergency Responders and Fit Testing
  212. Wind Socks… a critical piece of Equipment?
  213. Another how NOT TO RESPOND video (Ammonia Tanker)
  214. 1984 Mexico City BLEVE (1984)
  215. Crude Tank "Boilover" Explanation (2 Videos)
  216. Properties of Anhydrous Ammonia
  217. UPDATE - Calling the National Response Center
  218. 911 Call - 28-year old killed by forklift
  219. How NOT to respond to an Ammonia Leak!
  220. Anhydrous Ammonia Pipeline Rupture
  221. SCBA Cylinder Failure Incident
  222. Oxygen Depletion in Level A Hazmat Suits
  223. Ammonia Gas can deliver you shrink wrapped!
  224. New versions of ALOHA and CAMEO Chemicals are now available
  225. NIST Study Finds Failure Points in Firefighter Protective Equipment
  226. Comparing Results of Two Chlorine Release Field Experiments—Wild Stallion and Jack Rabbit
  227. Application of source term and dispersion models in developing Protective Action Distances in the Emergency Response Guidebook
  228. Siting of emergency response equipment & personnel?
  229. Does your ERP contain SPECIFICS?
  230. How do all the different levels of HAZWOPER training fit together and what level do I need to respond?
  231. PERFECT Example of a "Pre-Planning" lapse!
  232. Can your local Fire Department meet your needs?
  233. Who calls 911? (Alias: who-calls-911)
  234. Hands-On Railcars - Anhydrous Ammonia (Video)
  235. TRANSCAER® LAUNCHES ONLINE SAFETY TRAINING
  236. Off-Site Emergency Response Training Limitations
  237. Fire Door Basics
  238. Are all EXIT signs created equal?
  239. FIRE EXTINGUISHER FATALITY and inspections
  240. SIMPLE and CHEAP methods for on-scene medical monitoring
  241. What makes a "response" an "emergency response" under 1910.120
  242. Medical Monitoring of a HAZMAT Team
  243. Understanding 1910.120 as it applies to a HAZMAT team
  244. Liquid Nitrogen BLEVE Demo Vid #1
  245. Boiling Liquid Expanding Vapor Explosion (BLEVE)
  246. BLEVE Training Video Part 1 - EXCELLENT Info
  247. BLEVE Training Video Part 2 - EXCELLENT info
  248. Bleve Test - LPG Railcar (Video)
  249. 1983 Murdoch, IL LPG Railcar BLEVE (Video)
  250. BLEVE - Explanation from NFPA (Video)
  251. BLEVE Training Video
  252. States of Matter (Video)
  253. Standpipe Systems...What is required?
  254. Fire Hoses on Standpipe Systems...To connect or not to connect!
  255. The OLD and NEW IDLH and a little history about the MOST important term for any HAZMAT Technician
  256. Dangerous misunderstanding around a B.L.E.V.E.
  257. Ethanol Safety Organization for safety professionals and emergency response
  258. MSDS and Emergency Response Alert from EPA
  259. TRANSCAER schedules emergency response training tour for anhydrous ammonia
  260. Does my plant/site manager have to be trained in HAZWOPER?
  261. Chlorine Institute C-Kit Briefing Paper
  262. Your Emergency Response Plan (q)(2)(xii) Use of the Local Emergency Response Plan (LERP) or the State Emergency Response Plan (SERP)
  263. Your Emergency Response Plan (q)(2)(xi) PPE and Emergency Equipment
  264. Your Emergency Response Plan (q)(2)(x) Critiques of Response and Follow-up
  265. Your Emergency Response Plan (q)(2)(ix) Emergency Alerting and Response Procedures
  266. Your Emergency Response Plan (q)(2)(viii) Emergency Medical Treatment Procedures
  267. Your Emergency Response Plan (q)(2)(vii) Decontamination
  268. Your Emergency Response Plan (q)(2)(vi) Evacuation Routes and Procedures
  269. Your Emergency Response Plan (q)(2)(v) Site Security and Control
  270. Your Emergency Response Plan (q)(2)(iv) Safe Distances and Places of Refuge
  271. Your Emergency Response Plan (q)(2)(iii) Emergency Recognition and Prevention
  272. Your Emergency Response Plan (q)(2)(ii) Personnel Roles, Lines of Authority, Training, and Communication
  273. Your Emergency Response Plan Section (q)(2)(i) - Pre-emergency Planning and Coordination
  274. Emergency Response & PSM Tip
  275. What must be in my EAP?
  276. Do I Need an Emergency Action Plan?
  277. Fight or Flight
  278. From an EAP to an ERP???
  279. CHLOREP NextGen Bulletin
  280. How strong is your headcount procedure?
  281. WISER 4.4 is now available!
  282. Safety and Health Tip HAZMAT Evacuation iPhone App
  283. Thoughts of an Emergency Responder

Not a question we must know the answer to in order to be safe, but one that an old emergency responder ponders and now we know...

The National Institute of Occupational Safety and Health (NIOSH) defines an immediately dangerous to life or health condition as a situation

"that poses a threat of exposure to airborne contaminants when that exposure is likely to cause death or immediate or delayed permanent adverse health effects or prevent escape from such an environment"

This year’s active hurricane and fire seasons highlight the importance of working together before, during, and after disasters of all types and sizes. The National Incident Management System (NIMS) provides a common, nationwide approach to enable the whole community to work together to manage all threats and hazards.  FEMA has released the refreshed NIMS to ensure that this important guidance continues to reflect the collective expertise of the whole community. NIMS applies to all incidents, regardless of cause, size, location or complexity. Through an iterative process of engagement with stakeholders from across the nation, FEMA reviewed more than 3,000 comments to update NIMS guidance and incorporate the collective expertise and experience of the whole community.   The refreshed NIMS:

As almost everyone has felt the financial squeeze at some point during their career and we seem to be feeling it more and more these days. As auditors that travel the world, we are still seeing the negative ripple effects of the 2009/2010 recession in the United States in 2017 and probably will continue to see them in 2018 in the EHS arena. The effect I want to talk about in this article is the change from in-house emergency response training to using off-site/open enrollment type courses to meet the facility's emergency response training needs. This is NOT about bashing these off-site training organizations, as most of them provide a world-class level of training, but there is ONE HUGE FLAW in using them to meet all of our ER training needs…

 
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