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 Session No. 543 - Process Safety Management Best Practices, Lessons Learned and Enforcement Trend
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LOTO and Contractors
Safety Info Posts - Lockout Tagout
Written by Bryan Haywood   
Wednesday, 16 April 2014 21:10


A contractor is hired to make repairs to a piece of equipment. This work will require the machine’s energy sources to be isolated per 1910.147. The facility has a machine specific procedure for said equipment. Contractor follows the machine specific procedure and uses their company’s LOTO locks per their written LOTO program/practices to lockout this piece of equipment. Right next to this piece of equipment that has been isolated using the contractor’s LOTO locks is another contractor installing a new and identical piece of equipment. The contractor’s that performed the lockout used a very popular brand of silver locks - some with blue bands and some with yellow bands. The host employer’s LOTO program uses “color” to identify their LOTO locks and they use a solid red lock for their energy isolations. The site has a contractor safety orientation program for all contractors and during said orientation they train all the contractors that site LOTO locks are red in color.

Does this sound familiar to anyone? Maybe your facility has a contractor safety orientation where LOTO locks are identified by color, shape or size for all the contractors so that they may be able to identify LOTO locks. Maybe your facility allows contractors to isolate machinery/equipment using their own LOTO locks. If any of this sounds familiar, this article may be of interest.

Last Updated on Wednesday, 16 April 2014 21:33
EPA RMP Citations @ food facility (NH3 & $19,397 NOV and SEP of $38K for CS Rescue Team Gear)
Safety Info Posts - PSM and RMP Citations/Analysis
Written by Bryan Haywood   
Wednesday, 16 April 2014 17:23

The Respondent, at its stationary source, has one RMProgram covered process which stores or otherwise uses ammonia in amounts exceeding its applicable threshold of 10,000 pounds. Respondent has submitted and registered an RMPlan to the EPA for the stationary source. Respondent has developed an RMProgram accidental release prevention program for the stationary source. Based on an RMProgram compliance monitoring investigation initiated on February 14, 2012, the EPA alleges that the Respondent violated the codified rules governing the CAA Chemical Accident Prevention Provisions, because Respondent did not adequately implement provisions of 40 CFR Part 68 when it:

Last Updated on Wednesday, 16 April 2014 17:47
33 incidents & 0 updates (4/15/14)
Safety Info Posts - Incident Alerts
Written by Bryan Haywood   
Tuesday, 15 April 2014 18:54
Last Updated on Tuesday, 15 April 2014 19:01
2014 Photo of the Week #15 (Hearing Protection)
Safety Info Posts - Photo of the Week
Written by Bryan Haywood   
Saturday, 12 April 2014 17:42

Your guess is as good as mine!!!  I am merely guessing, but I would imagine this is TRYING to say that DUAL HEARING protection is required in the area.  Instead we ended up with... Like I said last week, it is all in how you SAY IT (or in this case SPELL IT).


Last Updated on Saturday, 12 April 2014 17:52
Ammonia behaving badly... it is suppose to rise! (Video)
Safety Info Posts - Emergency Response
Written by Bryan Haywood   
Saturday, 12 April 2014 00:00

MEMBERS UPDATE on 4/12/14 from Minnesota Department of Agriculture (MDA)... On October 31, 2012 at 6:00 p.m. while anhydrous ammonia (ammonia) field application assembly was making a turn at the end of the field, the hitch connection between the application/toolbar unit and the nurse tank failed. The break-away coupling device failed to disengage, causing the threaded fitting at one end of the withdrawal hose to fail resulting in the air release of ammonia.  The video illustrates the ammonia release.

Last Updated on Saturday, 12 April 2014 22:30
2014 Video of the Week #15 (Power of a Vacuum)
Safety Info Posts - Video of the Week
Written by Bryan Haywood   
Saturday, 12 April 2014 00:00

So often we hear about the vessels that go BOOM, it never hurts to remind us what can happen when we create a vacuum in a vessel.

Last Updated on Saturday, 12 April 2014 21:31
The Value of Self Assessments
Safety Info Posts - Motivational Safety Materials
Written by Bryan Haywood   
Friday, 11 April 2014 08:15

A little boy went into a drug store, grabbed a stool at the counter and pulled it over to the telephone. He climbed onto the stool so he could reach the buttons on the phone and proceeded to dial someone. The store-owner observed and listened to the conversation.

Boy: ‘Lady, Can you give me the job of cutting your lawn?’

Woman: (at the other end of the phone line): ‘I already have someone to cut my lawn.’

Boy: ‘Lady, I will cut your lawn for half the price of the person who cuts your lawn now.’

Woman: ‘I’m very satisfied with the person who is presently cutting my lawn.’

Boy: (with more perseverance): ‘Lady, I’ll even sweep your curb and your sidewalk, so on Sunday you will have the prettiest lawn in town.’

Woman: ‘No, thank you.’

With a smile on his face, the little boy replaced the receiver. The store-owner, who was listening to all this, walked over to the boy.

Store Owner: ‘Son… I like your attitude; I like that positive spirit and would like to offer you a job.’

Boy: ‘No thanks.’

Store Owner: ‘But you were really pleading for one.’

Boy: ‘No Sir, I was just checking my performance at the job I already have. I am the one who is working for that lady I was talking to!’

How is your performance these days? Take time, every once in a while, to gauge your job performance. Too many times we blame others for our mistakes or the situations in our life rather than ourselves. We need to take a close look at who we are and how we do what we do. And it pays to have the valuable input of those we work for and with. Then, once we have identified our strengths and weaknesses, we can consciously work on both as needed. Honest, hard work and dedication always pay off in one way or another. Even if our efforts go unnoticed by others, we have the pride and satisfaction of knowing we’ve done our best!

Safety Wayne

40 incidents & 3 updates (4/6/14)
Safety Info Posts - Incident Alerts
Written by Bryan Haywood   
Sunday, 06 April 2014 20:24
Last Updated on Sunday, 06 April 2014 20:31
What is your EPA Risk Management Plan “Hazard Index”?
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Saturday, 05 April 2014 16:07

One of the methods EPA uses to determine RMP inspection priorities is based on their use of the Wharton School’s Hazard Index, which is defined as 

“the sum over all chemicals of log2 (maximum quantity of inventory on-site/threshold), or, alternatively, as the number of chemicals times log2 of the geometric mean of the maximum-to-threshold quantity ratio.”

EPA has defined a “High Risk” facility as one that has:

  1. RMP WCS population ≥ 100,000
  2. Any accident meeting RMP reporting criteria within last 5 years
  3. Hazard Index ≥ 25

So do you know your facility's  "Hazard Index"?

Last Updated on Saturday, 05 April 2014 16:37
Yep, its JUST Anhydrous Ammonia "in Refrigeration" (Part II)
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Friday, 04 April 2014 11:23

UPDATED with the actual working EXCEL Spreadsheet so that members can sort the data as needed;as well I updated the #'s related to refrigeration below.  I had messed up my first sort and was off by a couple.  

This week I raised a red flag regarding ammonia accidents after the UNLOADING FATALITY at a fertilizer facility, only to be told that it was the wrong "forum" (e.g. ammonia refrigeration) to mention the hazards of ammonia at a fertilizer plant, after all we are "ammonia refrigeration" and not fertilizer plants.  It seems there still remains those who truly believe that Anhydrous Ammonia somehow behaves and has a different level of hazard depending on how and where it is used.  Granted, the level of risk in a process that has ROUTINE TEMPORARY connections such as a fertilizer distributor is one that is MUCH HIGHER than a closed loop refrigeration process; however, this in NO WAY implies there is little risk in such a closed loop process.  Anyone who hooks up a truck to their process can LEARN from the fertilizer accident and in truth, MOST ammonia delivered to refrigeration processes occurs in the spring and summer months as well!  So I have worked with an organization in analyzing many of the Ammonia Accidents that those of you who use the Incident Alerts have seen over the years.  Here is that accident data regarding the use of Anhydrous Ammonia in the refrigeration industry.  This data is world-wide and takes us from 2006 up to the last quarter of 2013.  This data is SPECIFIC to NH3 used in "REFRIGERATION".  In summary for the period of 2006- 3rd quarter 2013, there have been 93 fatalities from ammonia accidents in refrigeration, 877 injuries, 286 which were "severe" enough to require hospitalization, and 16,482 personnel evacuated.   These numbers correspond to minimum average GLOBAL frequencies of 120 injured, 30 severely harmed and 12 fatalities each year related to ANHYDROUS AMMONIA used in REFRIGERATION.  By comparison, a US survey (SAFTENG Members Access) on ammonia accidents showed an average frequency of 7 accidents and 2 fatalities/year between 1995 and 2006.  This article and data is for SAFTENG members and those who wish to use the data.   This is NOT a scientific study and ONLY media accounts were used in this analysis.  This means that ONLY those releases of Ammonia from a REFRIGERATION process that made the news were captured.  I will allow any deductions one comes to, to their own conclusions; however, the data is what it is.  Use at your discretion.

Last Updated on Friday, 04 April 2014 20:22

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