Chemical Process Safety (PSM/RMP)

California Announces Major Regulatory Proposal to Improve Safety at Oil Refineries

The Department of Industrial Relations (DIR), the Governor’s Office of Emergency Services (Cal OES) and the California Environmental Protection Agency (CalEPA) today announced a landmark set of regulations to strengthen workplace and environmental safety at oil refineries across the state.  The regulatory proposals are intended to make California refineries safer both for workers and surrounding…...

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NBIC’s NATIONAL BOARD BULLETIN hits a homerun for process safety practitioners!

As I have said in the past, the National Board publishes a FREE magazine, The Bulletin, each quarter that almost always contains information that we can use in our daily management of chemical processes. The best part of these FREE articles are they come from a VERY RELIABLE source and are written in such a…...

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FY 2016 U.S. Chemical Safety and Hazard Investigation Board Management Challenges (EPA Office of Inspector General)

Attention to CSB management challenges could result in stronger results and protection for the public, and increased confidence in management integrity and accountability.  Based on our continuous audit work, CSB public hearings, congressional hearings and CSB board meetings, EPA’s IG identified three (3) management challenges and one internal control weakness related to operational controls.  The…...

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Pressure Testing gone bad (Fatality)

On September 24, 2010, Employee #1 was standing five feet away from a pressure test being conducted with nitrogen. Inside the test, the cylinder was a downhole tool used in oil and gas production. For unknown reasons, the tool inside the test cylinder exploded knocking the threaded end cap off the test cylinder. The explosion caused the straps…...

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NBIC introduces a NEW Certification Mark for Pressure Relief Valve Certified Testing Organizations

The new T/O program formalizes the “Test Only” process by providing National Board certification to organizations conducting in-service testing of pressure relief valves. The program includes an adjustment for restoring nameplate set pressure and provides customer and inspector confidence in testing capabilities.  T/O Certificates of Authorization will be extended to current VR certificate holders. New applicants can obtain a T/O Certificate of Authorization by…...

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Managing boilers attached to a PSM/RMP covered process

Last week I posted a June 2016 OSHRC decision in which an Administrative Law Judge (ALJ) sided with OSHA on a number of PSM citations regarding a fatal boiler explosion that occurred within a PSM-covered process.  Since that posting, I have received dozens of e-mails asking for more explanation and how I suggest managing this…...

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OSHRC rules that a boiler providing steam used in safety systems is part of the PSM Covered Process

This case is not final orders of the Review Commission as it is pending Commission Review! This decision can have HUGE impacts throughout the PSM/RMP community, as many covered processes are “interconnected” to a boiler and many may also be “co-located” such that a boiler explosion could impact the covered process.  This case involved a boiler…...

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“Routine Process Openings” can be hazardous as well

This week I was privileged to be able to present as ASSE’s Safety 2016 on a topic near and dear to me… Line Break/Process Opening.  In our presentation, we mentioned “Routine vs. Non-Routine Openings” and how we manage these different openings.  One of the requests we received afterward was for “routine openings” that resulted in…...

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Downloading, Installing, and Running the Chemical Reactivity Worksheet (CRW)

This is the latest version of the Chemical Reactivity Worksheet (CRW) 4.0.0, which was posted on March 3rd, 2016 . Follow these instructions for downloading, installing, and running the CRW. NOTE: With the release of CRW 4.0 in March 2016, the ongoing management and distribution of the CRW have been transitioned to The Center for…...

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A baseline for Pressure Vessel Safety in the USA

Every once in a while we come across process vessels that are operating well above 15 psi and yet the vessel has no recognized design criteria and is far from being an ASME “coded vessel”.  Most of the time the client is happy we discovered this, but there are those who will always challenge the…...

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PSM/RMP Application and NFPA 704 Ratings

One of the top questions I receive is asking about how NFPA 704 ratings play into the application to OSHA’s Process Safety Management standard and EPA’s Risk Management Plan rule.  I hope to clarify any confusion this NFPA 704 application may be causing, as YES – the NFPA 704 does have a role in determining if…...

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