Chemical Process Safety (PSM/RMP)

This past week I was having a conversation with my friend and fine PSM professional Brian Chapin @ RCE and our discussion turned to diffuser tanks.  Having been involved in several design and install projects over the past several years, getting to know a little something about diffuser tanks comes with the territory.  But one of my…...

This incident shows us that just because a pipe contains a chemical that may not be included in a PSM/RMP program, it does not mean the level of risk is any less.  This explosion was caused by construction workers using a cutting torch to remove old piping from a boiler room and cut into a…...

2016 will go down as the year OSHA and EPA tried to revamp their PSM and RMP rules for handling Highly Hazardous Chemicals (HHC) and Extremely Hazardous Substances (EHS).  We have even seen Congress get into the act of blocking OSHA from enforcing PSM on fertilizer distributors.  All the while, our friends to the north have…...

For years, NFPA 70, the “National Electric Code” has exempted Engine Rooms/Mechanical Rooms for refrigeration processes using Anhydrous Ammonia from having to be Electrically Classified Hazardous Locations (HAZLOC) as long as the room had “adequate ventilation”.  The exemption in NFPA 70 has always been sort of vague and referenced the ventilation requirements in ANSI/ASHRAE 15-1994, Safety…...

Recently at a Compliance Assistance conference, OH-EPA presented on EPA’s Risk Management Plan and revealed some interesting data. One thing to state up front is that Ohio EPA is one of thirteen (13) states that has been delegated to enforce 40 CFR Part 68 within the state of Ohio. With that comes a snap shot…...

EPA has announced it will increase efforts to prevent catastrophic accidents and explosions that threaten employees and emergency responders and release chemicals that threaten human health and the environment in neighboring communities.  EPA selects National Enforcement Initiatives (NEIs) every three years to focus resources on national environmental problems where there is significant non-compliance with laws, and where…...

The state of IL has passed some Anhydrous Ammonia (NH3) regulations that will require retail Ag fertilizer businesses to:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

The House Appropriations Committee has approved language blocking OSHA’s efforts to cover Anhydrous Ammonia bulk processes located at “fertilizer businesses”. The legislation now awaits consideration on the House floor. The bill prevents OSHA from revising a previous enforcement position relating to the “retail exemption” (1910.119(a)(2)(i) that would pull around 4,800 anhydrous ammonia fertilizer facilities into…...

The U.S. Chemical Safety Board (CSB) has formally announced that “Emergency Planning and Response” and “Preventive Maintenance” are the Board’s newest “Most Wanted Safety Improvements”. The CSB has concluded that inadequate or poor emergency planning or response is a recurring finding in the CSB’s investigations. And that inadequate mechanical integrity programs, delayed or deferred preventive…...

For years now OSHA and EPA have taken similar approaches to how they view DOT containers (Tank Trucks and Railcars) when they are connected to a process.  Both agencies have stated that as long as the motive power (e.g. tractor or locomotive) remains in place then the unloading falls under DOT and thus the content…...