Chemical Process Safety (PSM/RMP)

What is the LOC/MOC in a flammable process?

I grew up using the acronym MOC, but I think it was confusing when PSM came out, since everyone thought MOC meant “Management of Change.” Now I don’t know if that is why they went with LOC (Oxygen Concentration), but that is what is used today. So what is LOC, and why does it matter…...

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EPA recognizes “bollards” as a safeguard

From at least August 20, 2025, until June 12, 2026, Respondent failed to ensure process equipment located in areas accessible to vehicles was protected from heavy machinery by means of bollards, guardrails, or other acceptable forms ofprotection, as required by 40 C.F.R. 68.65(d)(2), which directs owners and operators to ensure that equipment complies with recognized…...

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Does 1910.106(e)(2)(iii) require introduction of fresh air similar to provisions contained in §1910.106(e)(3)(v)(a)?

No. §1910.106(e)(2)(iii) does not require the exclusive use of fresh air for ventilation purposes. Additionally, 1910.106(e)(2)(iii) is a performance requirement and does not explicitly require the introduction of fresh air to meet the performance requirements of the standard. OSHA, under 1910.106(e)(2)(iii), expects employers to provide adequate ventilation to maintain concentrations below 25% of the LEL…....

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Did your PPE Hazard Assessment consider the use of FRC?

Most of my work as a consultant involves working in flammable liquid and gas process areas. I always wear my FRC if I am inside these areas and there is activity that necessitates I wear my FRC. Where did I get that list of activities? A 2010 OSHA LOI…… Membership Required You must be a...

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Is bonding and grounding an effective control when transferring non-conductive flammable liquids?

The short answer is no. While bonding and grounding are absolute regulatory requirements under OSHA 1910.106 and are foundational safety measures in flammable liquids safety, they are insufficient on their own when transferring non-conductive (e.g., conductivity < 50 pS/m) flammable liquids like toluene, xylene, benzene, or ultra-low sulfur diesel. This is a classic process safety…...

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The need for REMOTE Emergency Shutdown

I thought this image was a good way to show why Codes and standards for hazardous materials such as NH3 REQUIRE REMOTE Emergency Shutdown Systems. For example, CGA 2.1 states the following:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Former Yenkin Majestic Paint Corporation, which has since been sold to new ownership, pleads guilty to negligent endangerment

An Ohio corporation pleaded guilty this week in federal court in the Southern District of Ohio to a charge of negligent endangerment. The criminal charge is related to an explosion that resulted in the death of one employee and injuries to several more. Yenkin-Majestic Paint Corporation was a family-owned and operated coatings-industry supplier based in…...

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Operator seriously injured when sprayed by liquid NH3 after failure of flexible rubber hose

A process worker and colleague were preparing for a scheduled maintenance task in the ammonia storage area of a processing plant. As part of a routine purging operation, the process worker connected a flexible rubber hose to a purge connection point via a coupling. The purge hose was charged with nitrogen and the valve was…...

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The smallest change without an MOC review results in a serious fire

Transferring a flammable liquid, even in small quantities, can have very serious consequences. A former client who handles large quantities of flammable liquids had an event a number of years ago that was caused by what many never recognized as a “change,” especially one that would lead to such a serious event. Take a look…...

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BOLLARDS BABY! (NH3 release caused by PIT)

NOTE: I have no idea how a PIT can strike a PSV on a pressure vessel, but this is what was reported to have happened. A forklift at the facility struck a pressure relief valve on a 60,000-pound NH3 tank that contained 14,000 pounds of ammonia, the Sacramento Fire Department said. One person was injured…...

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NH3 unloading hose failure leads to serious injuries to worker and horses

A 35-year-old man suffered severe anhydrous ammonia burns to his upper body and lungs while he was unloading a semi truck with anhydrous ammonia when the liquid hose failed. Liquid NH3 doused the man’s face and entered his lungs, the Marion County ambulance director said. The man was taken by helicopter to Ascension Via Christi…...

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