Incidental Release or Uncontrolled Release of NH3 - What say you?
So you have to make the call... Is this an incidental release or would this release rise to the level of sounding the alarm, evacuating the engineroom - thus making this an emergency response?
Another MI learning opportunity with regard to corrosion in piping
This is another lesson’s learned regarding piping and its mechanical integrity. On October 6, 2011, an explosion and subsequent fire occurred in the Middle Distillate Unifiner (MDU) area at a Canadian refinery and injured 52 workers. This third party analysis of the piping involved and its failure mode paint an ugly picture of how improper MI management can lead one to misunderstand the true condition of their piping. The incident also points out that changes to processing conditions can have a long-term impact on the MI of piping (and vessels as well). In this case, a change in process conditions created more water vapor in the pipe that failed and this factor lead to increased corrosion rates; however, the refinery did not recognize this and therefore did NOT increase their inspection/testing frequencies on the piping. EVERYONE who participates in process safety should take the time to read this report and ask the question... "Could this happen here?" Here is the report summary and link to the full report...
OSHA PSM Citations @ nail polish manufacturer (Flammables & $139K)
OSHA found plant workers and temporary workers employed by two staffing agencies were exposed to hazards and other dangerous safety and health violations at the plant. The inspection resulted in 30 OSHA citations against the nail polish manufacturer and staffing agencies. Proposed penalties total $139,500. The plant faces $109,500 in penalties for 23 serious violations, which exposed plant employees to fire, explosion and safety and health hazards related to flammable chemicals. Inspectors found the plant stored thousands of pounds of flammable liquids on-site in indoor storage tanks. One tank overflowed in July 2014 because of a disabled or broken safety mechanism. Here is a breakdown of the PSM related citations:
Safety Alert - PROHIBITED REFILLING OF DOT 39 SPECIFICATION CYLINDERS
PHMSA has become aware of the sale of adapters designed to allow refilling of DOT 39 cylinders using larger cylinders (see attached photographs). These adaptors are sold at various retail outlets and online. Some of the common trade names are the “Mac Coupler”, “Mr. Heater” and “Shnozzle”. “MacCoupler” is manufactured by KM North America in Traverse City, MI. “Mr. Heater” and “Shnozzle” are manufactured in China and sold on Amazon. Additionally, several websites demonstrate how to use these adaptors.
PHMSA strongly recommends that the general public refrain from refilling DOT 39 cylinders because of the one-time use design of these cylinders, and the purchase and use of any adaptor sold as a means to refill DOT 39 cylinders creates a potential risk of fire, explosion, serious injury, and property damage.
CLICK HERE (pdf) for the full alert.
2014 Photo of the Week #51 (Electrical LOTO)
Falls a bit short of 1910.333(b)(2) don’t you think?
"Lockout and Tagging." While any employee is exposed to contact with parts of fixed electric equipment or circuits which have been deenergized, the circuits energizing the parts shall be locked out or tagged or both in accordance with the requirements of this paragraph. The requirements shall be followed in the order in which they are presented (i.e., paragraph (b)(2)(i) first, then paragraph (b)(2)(ii), etc.).
2014 Video of the Week #51 (5 FAQs on GFCI from NFPA)
With all the Christmas decorations up and all the cords running everywhere I thought this would be a good reminder. As for work, remember since 2008 GFCI's are required when workers are using electrical cords and corded tools that are used during construction-like activities, including certain maintenance, remodeling, or repair activities, involving buildings, structures or equipment (1910.304(b)(3)(ii).
Interesting PSM/RMP nuggets from the 12/11/14 Senate hearing on EO - IMPROVING CHEMICAL FACILITY SAFETY AND SECURITY
Reading through the opening comments from OSHA and EPA at this weeks Senate Committee hearing discussing Executive Order 13650 - Improving Chemical Facility Safety and Security offered us some very interesting insights as to what OSHA and EPA are doing and planning in their efforts to improve process safety. Here are some of those that I found most interesting.
The fundamentals behind “line breaking”
My article earlier this year about line breaks on relief valve vent lines that are attached to a header/manifold got a lot of you to ask more questions about the practice of “line breaking” (or as some call it “process opening”). I have tried to answer each question, but thought it may be helpful to explain the fundamentals of safe line breaking. As we know, “line breaking” is the one safe work practice that OSHA and EPA mention in their process safety standards yet provide ZERO guidance on. We can not even find a RAGAGEP or consensus standard for guidance; however, we do have some excellent historically practices we can rely on.
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