Chemical Process Safety (PSM/RMP)

How strong is your MI “Quality Assurance Program”?

Both OSHA and EPA require PSM/RMP facilities, more specifically covered process(s), have a QA program in their Mechanical Integrity (MI) Program… 1910.119(j)(6) Quality assurance. 1910.119(j)(6)(i) In the construction of new plants and equipment, the employer shall assure that equipment as it is fabricated is suitable for the process application for which they will be used. 1910.119(j)(6)(ii) Appropriate checks…...

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Pipe flanges and process safety

As a process safety professional, what do we see and what comes to mind when we see a pipe flange like the one shown here?  In this small and simple picture, how many sections of OSHA’s PSM standard (or EPA’s RMP rule) impact this pipe flange; better yet, can we name all the RGAGEPS that…...

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Intrinsically SAFE instrumentation MATTERS (digital pressure gauge caused explosion that severed arm)

UPDATE 10/18/2016 – Hawaii Occupational Safety and Health Office reduced the number of violations cited from 15 to nine and lowering fines from $115,500 to $69,300.  About a month after the blast, the Honolulu Fire Department said its investigation determined the explosion was likely caused by a digital pressure gauge in the tank that produced an…...

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An OSHA PSM or an EPA RMP inspection is NOT a 3-year audit

Full disclosure, I do PSM/RMP audits, but that does not change the facts that I will present in this article. Over the past couple of years, I have seen first-hand companies cancel or fail to schedule their 3-year PSM/RMP audits because their State EPA, Federal EPA or OSHA did a PSM/RMP inspection at their facility…...

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What does 527 CMR 33.00: Hazardous Material Process or Processing have to do with the Boston NH3 Fatality?

On March 23rd a worker at a seafood processing building/warehouse in Boston, MA was killed in a catastrophic release of anhydrous ammonia. Since then there has been much speculation as to how this tragedy occurred and whether or not the facility’s refrigeration process fell under OSHA’s PSM and EPA’s RMP standards. As it appears at…...

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A functioning weak roof-to-shell seam on Diesel Tank (Hot Work Fire Video)

One of the means to protect an OUTSIDE atmospheric storage tank is a weak roof-to-shell seam.  As we can see in this video, a diesel tank at a wharf in Apia, Samoa was equipped with such a means of fire venting.  I am assuming this on the basis of the information we can obtain from the…...

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Using a pressure vessel that does NOT carry the ASME Stamp in the state of CA?

Sometimes I come across some items as I do work for clients that are priceless in helping us make our case for safety and this one is a “feather in our [hard] hat”.  Apparently some employers in the state of California decided that using pressure vessels built to some code other than ASME Section VIII…...

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1998 BLEVE Aniversary

On April 9, 1998, an 18,000-gallon propane tank exploded (BLEVE) at the Herrig Brothers farm in Albert City, Iowa. The explosion killed two volunteer firefighters and injured seven other emergency response personnel. Several buildings were also damaged by the blast.  CLICK HERE for the CSB Report…. Membership Required You must be a member to access...

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A part of process safety history ending this week (70 ton CL2 release)

This week we got word that the Olin Corp has announced that they will be reconfiguring their Henderson, NV facility to make bleach.  This is the facility that in 1991 when owned and operated by Pioneer Chlor Alkali Company, Inc. had the largest Chlorine release on record, 70-100 tons of chlorine.  The response to the…...

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Proud moment for SAFTENG

Imagine my surprise when reading the latest edition of “Chemical Process Safety (Fourth Edition), Learning from Case Histories“, August 2015, by Roy E. Sanders when I came across a very nice mention of SAFTENG.net.  In 2014 I received some very nice feedback from Mr. Sanders regarding my work with the Incident Alerts and my Process Safety…...

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When does a process safety nearmiss become an incident that needs to be investigated

One of the weakest elements in OSHA’s PSM and EPA’s RMP standards is the Incident Investigation element.  Anyone who has performed a PHA or Audit can tell you that the difference of opinions range from aggressive to the criminally insane!  Personally I have heard some of the lamest excuses for not investigating Loss of Primary…...

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OSHA’s GDC for Nitrogen Pressure Vessel Manifold Failure Fatality

The accident occurred on Friday 6/14/2013 at around 6 p.m. in a section of the plant that had been shut for maintenance when a nitrogen vessel ruptured during off-loading. The blast killed one worker and sent seven others to the hospital. OSHA investigated and issued the following 5(a)(1) citation regarding the design of the process…...

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