Chemical Process Safety (PSM/RMP)

  P1 P2 P3 Third-party audits (applies to the next scheduled audit after an accident)   √ √ Incident Root Cause Analysis (only for facilities with accidents/near misses)    √ √ Safer Technologies Alternatives Analysis (STAA) (applies to a subset of P3’s in certain NAICS codes)      √ Coordinating Emergency Response Program Requirements with…...

One of the more common misses by a lot of businesses, especially those using pressure vessels (PVs) in their PSM/RMP covered processes, is the “initial inspection” at the time of installation.  We have discussed the “change of service” inspection several times; however, this inspection is for NEW PVs being installed.  This requirement will certainly apply…...

EPA recently announced its enforcement and compliance assurance priorities for fiscal years 2020 to 2023. There are seven (7) priority areas in total for this period, six of which are National Compliance Initiatives (NCIs), which will be led by EPA’s Office of Enforcement and Compliance Assurance.  The one that I follow closely is…… Membership Required...

In the recent OSHRC decision where the ALJ decided that “tight-fitting” doors for an engine room/machinery room doors were not a PSM requirement since “doors” were not part of the covered process. What is confusing is that the company successfully convinced the ALJ that ASHRAE 15 was not their chosen RAGAGEP (even though they stated…...

With today’s announcement of the OSHRC decision that the IMC was the facilities RAGAGEP and that the IMC does not require detectors, I thought this record needs to be CORRECTED and CLARIFIED, as the ALJ’s understanding of how the IMC and its requirements apply to an ammonia refrigeration process/system.  In the decision, the facility successfully…...

This 2019 OSHRC decision is without a doubt the worst excuse for process safety I have seen since I have been involved with process safety (27 years).  This case fails to meet the most fundamental basis of how OSHA’s wrote the standard.  Employers get to pick their RAGAGEPs, but when they state the “codes and…...

The information in this report is preliminary and will be either supplemented or corrected during the course of the investigation. On April 25, 2019, about 4:33 a.m. central daylight time, about 750 gallons (3,800 pounds) of anhydrous ammonia liquefied compressed gas (UN1005, Division 2.2) were accidentally released from two 1,000-gallon nurse tanks mounted on a…...

This week we saw two Canadian businesses be fined over $1.2 M (CAD) for discharging their “Ammonia bleed water” to a storm drain which discharged into a river killing around 70 fish. The business, a University in British Columbia, hired a refrigeration contractor to make repairs to the refrigeration system, at which time the contractor…...