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Examination and Testing of NON-metalic piping systems (ASME B31)
How times have changed in 30 years regarding "materials of construction" in hazardous materials processes. I grew up in process safety, seeing nothing but metallic piping systems; today, I bet I see piping systems made from non-metallic products upwards of 25% of the time. This is becoming increasingly acceptable in one specific process I do a lot of work with, so I can not provide specifics as it could create a trail back to some of my clients. Just know that many of the processes are PSM/RMP-covered processes. ASME B31.3 addresses non-metallic piping systems in Chapter VII, Nonmetallic Piping and Piping Lined With Nonmetals. In this article, I want to discuss Part 10, Inspection, Examination, and Testing of Nonmetallic Piping Systems Used in a PSM/RMP-covered process. For those who are not SAFTENG members, just know that ASME B31.3 requires many of the same examination and testing requirements for nonmetallic piping systems as it does for metallic piping systems. Two (2) very CRTICIAL PROHIBITIONS for non-metallic piping are the SAME as metallic piping:
Here are the other examination and testing requirements for NON-metallic piping systems: Membership Content
Top 5 signs your not managing safety via a SMS
This article applies to BOTH facilities practicing process safety and basic OSH. Many of the facilities will declare they have and utilize a Safety Management System (SMS) in their efforts to manage hazards and risks those hazards pose to workers, the environment, and the business. However, I have developed five (5) simple tests to determine if the facility is managing safety/process safety via an SMS. Please remember that a facility that requires a PSM/RMP management system is REQUIRED to use these tools. Still, over 20+ years of performing PSM/RMP audits, we can conclude that many businesses struggle to meet the management system requirements. [My] Weekly Thought on Safety... give a SMS a chance
In the social media "safety sphere," it is literally impossible to spend five minutes and not be bombarded by all the new approaches to "safety." In many of these new approaches, they will almost unilaterally denounce the traditional approach to safety management and provide case studies to prove their point. Maybe I am just an old dog and can't learn these new tricks, or I have seen what a formal Safety Management System (SMS) can do for an organization and believe in the SIMPLE approach. In these studies, where they debate and attempt to convince me of the need for a new approach (name your choice of the many new approaches), they will usually demonstrate the ups and downs of performance using the older traditional methods, such as a formal SMS. We can all nod in unison as we have all lived this turbulent performance (e.g., OSHA-free last year, only to have three recordables already before April!). But here is what I have noticed over three decades of building SMSs... Very few organizations have a fully functioning SMS, much less a mature SMS. This observation even applies to many organizations mandated to have an SMS because they call under OSHA/EPA process safety standards. So, is it a flawed approach, or is it a lack of dedication to a formal and structured SMS? What am I saying when I sign-off on the first line of my PSSR? (Piping)
Most PSSR forms we encounter simply regurgitate OSHA's 1910.119(i)(2). If the user is thoroughly knowledgeable of what each of these four (4) line items entails, we may be able to execute the PSSR appropriately. Let's look at these four line items, especially the first line.
This single line item, (i)(2)(i), INCLUDES a ton of responsibility, as well as documents/data, to embrace what it is attempting to achieve fully. This line item covers EVERYTHING (physical object) the HHC/EHS touches; however, I will discuss only how it impacts PSM/RMP piping in this article. We see a lot of PSSR in our travels, and almost all of them will have this line item signed off as completed; however, when we ask for piping installation records, we get the "deer in the headlights" look. Here is what a facility should have to sign off on this single PSSR line item properly: ASME B31 Examination vs. Inspection
The two (2) terms sound similar and will conjure up similar images when we hear them, but they are used in the ASME B31 piping standards in very different ways and apply to different groups. To state it very simply, the EXAMINATION is what the owner/operator does to pass the INSPECTION, which is what the Authority Having Jurisdiction (AHJ) does. In summary
Examination applies to quality control functions performed by the manufacturer (for components only), fabricator, or erector. Reference in this Code to an examiner It is the owner’s responsibility, exercised through the owner’s Inspector, to verify that all required EXAMINATIONS and TESTING have been completed and to inspect the piping to the extent necessary to be satisfied that it conforms to all applicable EXAMINATION requirements of the Code and of the engineering design. For many of you managing a PSM/RMP covered process, the actual work/requirements of B31.3 are inside the "examination bubble," which is where the heart and soul of the Quality Assurance measures come to life, such as: Safety Thought of the Week... Employee Engagement
The business benefits to be obtained from employee engagement are huge. Studies have shown that (a) where employee engagement was low, companies had 62% more safety incidents (Harter, Schmidt, Killham, & Asplund, 2006); and (b) where employee engagement was high, engaged employees were five times less likely to experience a safety incident, and seven times less likely to have a lost-time safety incident (Lockwood, 2007) than non-engaged employees. Employee engagement is an approach designed to help ensure employees are committed to an entity’s goals and values while motivating people to contribute to that entity’s success. Such entities tend to possess a strong and genuine value for workforce involvement, with clear evidence of a ‘just and fair’ culture (Reason, 1997) based on mutual respect between the entire management structure and the workforce. The key aspect is ensuring an understanding by all concerned that engagement means two-way dialogues that lead to joint decision-making about the best way forward while also acting together to make things happen:
Source: Safety Cultures, Safety Models, Taking Stock and Moving Forward, 2018, Claude Gilbert, Benoît Journé, Hervé Laroche, Corinne Bieder Corroded internal tube in Heat Exchanger leads to NH3 release
An internal failure of a heat exchanger caused ammonia gas to leak through and absorb into the circulating liquid brine for the underfloor loop. The ammonia within the liquid brine spilled out of the expansion tank, pooling within an open sump in the mechanical room. The heat exchanger needed to be replaced as it was not repairable. The failure of the exchanger was internal between the ammonia hot gas side and the calcium chloride liquid brine side. This caused ammonia gas to escape, be absorbed by the brine side, and escape out of an open-to-atmosphere expansion tank. The heat exchanger was isolated and stopped the flow of ammonia gas over to the brine side, and as a result, there was no underfloor brine heating available to the ice rinks affected as the pump was locked out and isolated. The heat exchanger failure was caused by an internal tube failure due to corrosion caused by a failure to maintain brine chemical and system levels, which allowed oxygen to attack metal internal surfaces. Internal corrosion caused by the lack of brine system maintenance is the most likely cause of the failure.
CLICK HERE for the full report Which speed control sign is most effective, and which would be the least effective?
Let's have a little fun while we challenge your knowledge of human factors. Which speed control sign is most effective, and which would be the least effective?
NOTE: If you have attended one of my safety training courses where I use this in the HF training, don't ruin it for others
EPA RMP citations @ ice cream plant (NH3 & $176K w/ $85K SEP)
Respondent owns and operates an ammonia refrigeration system at its ice cream novelty manufacturing facility, which maintained a maximum inventory of the regulated toxic substance anhydrous ammonia at the Facility, exceeding the threshold quantity of 10,000 pounds of anhydrous ammonia. The ammonia refrigeration system at the Facility services 3 freezer rooms and consists of 12 compressors (including compressor BC-02), 46 vessels, 23 evaporators, 1 purger, 32 heat exchangers, 2 condensers, 8 ammonia pumps, and 3 water pumps (the Covered Process). Episode 122 - Bryan Haywood - Permit and Non-Permit Required Confined Spaces
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