Chemical Process Safety (PSM/RMP)

The Courier-Journal has released more photos. Below is my analysis of these photos, using their and Google Maps road images. The first image below is the PRE-EXPLOSION image. In it, we can see the two (2) standing cooling towers/condensers. The one in the blue box is the one that was destroyed and came to rest…...

This week, we saw a fatal explosion in Louisville, KY. This same facility, albeit under a previous ownership, had a catastrophic failure of a PV in 2003. The photos coming out of the post-analysis of this week’s event look to be a similar type of explosion. CLICK HERE to see the pics. Here is my…...

Inspections As of the 3rd quarter of the fiscal year (Q3), EPA completed 133 CAA Section 112(r) (Risk Management Program) inspections. Enforcement Cases As of the 3rd quarter of the fiscal year (Q3), EPA took action at 73 facilities to decrease the likelihood of chemical accidents.  Sasol Chemicals: In April 2024, EPA finalized a settlement…...

One of the acceptable “protection techniques” for electrical enclosures within a Hazardous Location is to “pressurize the enclosure.”  Here are the three (3) Types of Pressurized Enclosures and the HAZLOC they are permitted to be used, and their design basis: NFPA 70, 500.7, (D) Purged and Pressurized. This protection technique shall be permitted for equipment in…...

In process safety, we spend a lot of time discussing the PRIMARY containment systems; however, our secondary containment systems play a vital role in our PROTECTION and MITIGATION layers of protection. Of course, we want to keep the tiger in its cage, but we also need to be prepared for the day it gets loose,…...

When we encounter a manufacturing facility that has been pulled into OSHA’s PSM or EPA’s RMP, we are almost certain to find the same design features for the emergency stop functions (i.e., E-Stops). Most of these facilities are shocked to learn there is a big difference between the location of an E-Stop on a machine…...

I believe in Excess Flow Valves and Check Valves, even though I have seen them fail more often than work as hoped. However, these failures are “human failures” in the incorrect design (e.g., sizing and placement) of the process where these valves are utilized. The valves are highly reliable when they are DESIGNED, INSTALLED, and…...

Some Excess Flow Valves (EXFVs) models can be placed into a position that would render them useless in their intended function. I have encountered this scenario more than once during my PHAs, Investigations, Audits, etc. There are not many manufacturers that incorporate this failure mode in their designs, but there a couple that do; and…...

What prevents excess flow valves from closing when the line breaks?  There are plenty of things that can prevent EFVs from operating as designed.  These include design failures, mechanical failures due to poor or no maintenance, and “human failures.” 1. Not a Clean Break For one or a combination of the following reasons, excess flow…...

I am aware that NFPA 58 applies to LPG installations; however, with the “dumbing-down” of many RAGAGEPs, I am always looking for the BEST DESIGN for my process safety functions. I do wish the IFC would define/quantify where remote activation stations must be, as they did decades ago. But for now, I use NFPA 58,…...

Hose failures during the unloading/loading of HAZMATS are still causing many problems for far too many businesses.  We have discussed the process side and the DOT container site engineering requirement for when the hose fails.  This post is a list of requirements that we should be incorporating into our HAZMAT safety programs regarding the use…...