Chemical Process Safety (PSM/RMP)

Managing your HFO-1234yf BLEVE risk (Part 6)

A few months ago I wrote about this new refrigerant as having the catastrophic risk of a BLEVE event. Now I wish to offer some guidance on how a business utilizing this refrigerant can reduce the likelihood of this type of event.  First, there are NO engineering standards that guide a manufacturer of an ASME…...

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OSHA PSM citations @ chemical manufacturer (Flammables & $66K)

On Jan. 19, 2016, the Hartford Area Office cited a chemical manufacturer for 15 serious violations of workplace safety standards. Inspectors found that a manufacturer of swimming pool chemicals and acetone preparations used in nail polish were exposed employees to chemical, fire, and exit access hazards. The company’s manufacturing processes use large amounts of the…...

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Failure of Relief System results in two (2) fatalities (WorkSafeBC)

At the site of an inactive gas well, two workers were flowing the high-pressure gas from the well to determine production potential. They were inside an operator’s shack when a pipe ruptured, and the escaping flammable gas exploded in a fireball. Although the two workers were wearing fire-retardant clothing, they suffered burns. The smaller piping…...

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FRESH AIR intakes for a ventilation system need to be from a source of FRESH AIR!

We continue to see the “check the box” engineering when it comes to “ventilation” requirements for processes that fall under PSM/RMP. I have written about the design basis and the many flaws we come across regarding the actual design, but this one is becoming more and more prevalent. I am thinking “space” is becoming less…...

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Butterfly valves and relief valve line isolation

This week I participated in an on-line discussion regarding a new “telltale indicator” that is being used in refrigeration processes. A really neat device that will indicate when an RV has lifted; however, I questioned its design and whether or not it could be considered an “obstruction” in the RV vent line. This device has…...

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Example of IMPROPER welding on pressure vessel(s)

Catastrophic results can occur when unauthorized repairs are performed on pressure vessels. An improper weld on an anhydrous ammonia nurse tank was a factor in a nurse tank failure that occurred on April 15, 2003, near Calamus, IA. resulting in one fatality and one serious injury. This is a stark reminder of the serious consequences that can occur as…...

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OSHA’s Interim PSM Enforcement Policy (December 23, 2015)

OSHA’s Process Safety Management (PSM) Standard states that its requirements do not apply to “retail facilities.” 29 CFR 1910.119(a)(2)(i).  On July 22, 2015, OSHA issued a memorandum entitled “Process Safety Management of Highly Hazardous Chemicals and Application of the Retail Exemption (29 CFR 1910.119(a)(2)(i))” (Memorandum). In the Memorandum, OSHA interpreted the term “retail,” as used…...

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EPA Risk Management Plan (40 CFR Part 68) revisions being considered

Here is an inside look at what EPA is considering in their revisions of their Risk Management Plan (RMP) rule.  These items are ONLY being CONSIDERED and DISCUSSED and are in NO WAY concrete changes that have been agreed upon.  Here are the six KEY areas currently in discussion: Third-party audits (applies to the next…...

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Process Opening/Line Break Accident due to IMPROPER LOTO (Government of Western Australia)

During “routine maintenance”, a process operator was cleaning an inline filter connected to pipework below a thickener tank. He opened the drain valve to verify isolation before undoing four bolts to open the inline filter door. On opening the inline filter door, the operator found the screen/filter full of material. As he pulled the screen/filter out of its…...

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Risk Management Plan (RMP) Facilities by the numbers (12/2015)

Here are the most up-to-date numbers regarding “RMP Covered” facilities as of 12/20/15), broke down by: Industry Program Level Small vs. Large… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Worked Example of how a Category 1 Flammable Gas process can be DESIGNED so as to NOT be a PSM Covered process

Over the past several years car manufacturers have been making the change over to their new GW reduction refrigerant which just happens to be a Category 1 Flammable Gas, thus making this material a Highly Hazardous Chemical in the eyes of OSHA. And when we have over 10,000 pounds of this HHC in our “process”…...

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