What if the quantity in the RMP Covered process fluctuates?
What if the quantity in the process fluctuates? I may not have a threshold quantity now, but I will intermittently exceed the threshold quantity.
Worst-case release from smaller process with larger distance to endpoint
The owner or operator of a stationary source covered by the risk management program regulations must conduct a worst-case release scenario analysis as part of the required hazard assessment (40 CFR §68.25). The worst-case release is defined as the release of the largest quantity of a regulated substance from a vessel or process line failure
Administrative controls considered when determining worst-case release quantity
For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity (40 CFR §68.25(b)). Why did
25-Ton Container of Chlorine dropped and catastrophic failure
Below is a video of a tragic accident that occurred today in Jordan’s Aqaba shipping port. A 25-Ton ISO Container of Chlorine (Cl2) (like the image to the left) was being lifted off a truck and onto a ship when somehow the container was dropped (too early to know the cause). The video shows the
Sustained inattentional blindness in expert observers
This is one for all the Behavior-Based Safety Observation admirers who somehow convinced themselves their BBS process is flawless. Most of us in the safety profession has seen the “gorilla and basketball” video. The study used a video made famous by earlier “inattention blindness” research featured in the 2010 book “The Invisible Gorilla,” by Christopher
Hexane explosion in an oil extraction plant (Double Fatality – PRCS)
The accident occurred in the hexane-based rapeseed oil extraction process. After grinding the seed and obtaining meal that is then steam-cooked (100°C), pressing in a continuous screw press is used to obtain 2/3 crude oil and flakes containing 1/3 oil. This oil is extracted from the flakes in the extraction process: the flakes are transported
EPA issues RMP citations @ water treatment facility (WRONG CHEMICAL – WRONG TANK incident, 2,000 lb Cl2 release & $66K)
Chlorine, CAS No. 7782-50-5, is an extremely hazardous substance regulated and listed in 40 C.F.R. § 68.130. As the owner and operator of a stationary source, with respect to the use and storage of ferric chloride and sodium hypochlorite, Respondent has a duty under the General Duty Clause, Section 112(r)(1) of the CAA, to design
EPA issues RMP citations @ poultry processing facility (NH3 & $124K)
The Respondent processes and freezes poultry products for distribution. The Respondent has two systems which include Anhydrous Ammonia at the Facility. The Respondent had one RMP program level 3 covered process (anhydrous ammonia refrigeration systems) which store or otherwise use a regulated substance in an amount exceeding the applicable threshold. The Respondent’s poultry freezing processes
Cal/OSHA Cites Four Employers $1.75 Million for Safety Violations in Death of Worker at a refinery
The Cal/OSHA Process Safety Management Unit has cited a refinery and three contractors a combined $1,753,375 for serious safety violations following a confined space death of a 35-year-old worker who suffocated in a regenerator overflow well. Cal/OSHA inspectors cited three of the four employers with willful and serious violations after determining that they failed to
The Hierarchy of Responses, How Hazards Sink to the Bottom
I am not sure who came up with this, but it is a classic example of far too many organizations.
The Safety Process through the eyes of a Quality Assurance Process
As many of you know I have taken on a new client (full time) in 2022 and my role in this organization is to build a safety management system (SMS). And let me tell you what, if you thought explaining a RAGAGEP to management was difficult – try explaining that safety is a “process” and
EPA issues RMP citations @ chemical manufacturing facility (Cl2, CHCl3, CH3Cl, C2H3Cl & $500K)
The respondent is the owner and operator of a chemical manufacturing facility. EPA conducted an inspection of the Facility on May 1-4, 2018, to determine the Respondent’s compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. The following chemicals are “regulated substances” pursuant to 40 C.F.R. § 68.3. The threshold quantity for