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EPA RMP GDC @ chemical facility (Xylene Release due to overfilling RX & $31K)

The facility uses xylene as a cleaning agent to clean the reactors. Xylene is an extremely hazardous flammable substance, and is stored at the facility. On August 14, 2017, at 11:24am, an operator was cleaning the RX-2 reactor with xylene between tolling processes. The operator overfilled the reactor with xylene, leaving the reactor without a vapor space…....

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EPA’s 2017 RMP Amendments Compliance Obligations

Due to a September court decision that vacated the RMP Amendments effective date delay, and the court’s expedited issuance of its mandate, the FINAL RMP AMENDMENTS RULE IS NOW IN EFFECT. Because the 2017 rule contains a schedule of compliance dates for many of the major provisions, the issuance of the mandate does NOT create current compliance obligations…...

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Fatal Explosion – catalyst Raney nickel was exposed to air during cleaning

NOTE: the text below is a translation from Chinese to English At about 13:49 on May 3, 2018, a catalyst explosion occurred in the hydrogenation reactor of No. 1 hydrogenation reactor of a Pharmaceutical facility causing one death and an immediate economic loss of 1.446 million yuan ($216,061,320 USD).  According to the “Safety Production Law of…...

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Technical Safety BC Workshop pinpoints two factors behind ammonia releases

Technical Safety BC conducted an ammonia release fault tree workshop to identify potential causes of ammonia releases from industrial refrigeration systems used in arenas and food storage facilities.  The workshop is part of a Technical Safety BC project meant to detect and mitigate emerging and known technical safety risks in the province. The project used the…...

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Can compressed air be used for pressure testing refrigerant piping?

As most process safety professionals know, pressure testing and leak testing piping systems is an absolutely critical function of process safety efforts.  And I am happy to say, the number of facilities that have begun pressure testing and leak testing their piping has grown by leaps and bounds since the passage of OSHA’s PSM and…...

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BSEE Safety Alert – Fired Vessel Hazards Identified in Risk-Based Inspections

The Bureau of Safety and Environmental Enforcement (BSEE) recently conducted a review of recent compliance and incident data to identify safety trends throughout the Gulf of Mexico. The analysis pointed to a potential risk associated with fired vessels. From January 2016 to May 2018, 17 fired vessel incidents were reported to BSEE by 12 unique…...

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EPA Region 6 RMP Inspection (hydrazine, methyl‐hydrazine, and 1, 1‐Dimethylhydrazine)

EPA Region 6 inspector arrived on May 1, 2018, for an announced inspection with an inspector from the Louisiana Department of Environmental Quality (LDEQ). The scope of the inspection was a partial compliance evaluation (PCE) and included an evaluation of the compliance of the facility. On April 18, 2018, the facility received an announcement email…...

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EPA Region 6 RMP Inspection Report (Chlorine Process)

Environmental Protection Agency (EPA) Region 6 Inspector (1) and Louisiana Department of Environmental Quality (LDEQ) Inspectors (3) arrived at the facility on May 1, 2018, for an announced inspection. On April 19, 2018, the facility received an announcement email, which outlined the directions for conducting an on-site inspection, as well as a list of documents…...

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EPA RMP Inspection prior to Start-Up and RMP Applicability

I came across this EPA Region 6 RMP inspection report while doing some research for a client and this is an amazing insight into the difficulties and details of implementing a Process Safety Management System. I always take out names and company names when I post inspection reports, as it is NEVER about the company,…...

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2018 Video of the Week #40 (More from the files of “I’m safe… see I have on my Hi-Vis vest”)

If only actual safety could catch on like the “Hi-Visibility Vest” movement has taken hold.  I am not knocking the concept of making workers more visible around mobile equipment but as this video shows us, there is SO MUCH MORE to safety than handing out “safety vest”.  They’re not a cap for superheroes!  How many…...

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