The decision by the OSHRC settles several KEY PSM application debates. The accident involved a boiler that provided steam to a covered process and the boiler also used fuel from the refinery process(s) so OSHA took the position the boiler was part of the “covered process” because it was both interconnected and co-located such that…...
After unscheduled maintenance to drain oil from the pumps, the refrigeration system was noted to be slow to return to performance and oil contamination of some system evaporators was suspected. The responding refrigeration mechanic stated he attempted to improve system performance by closing valves to generate pressure within an evaporator to move or dislodge potentially…...
As barriers or safety systems can fail, it is essential to design them well and understand their reliability, which is expressed in an SIL rating. The Safety Integrity Level relates to the Probability of Failure on Demand (PFD). We use complete orders of 10 to describe the reduction factor:… Membership Required You must be a...
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At 4:30 p.m. on March 15, 2018, an employee was performing a pressure test on a pump. Sulfuric acid of 93% concentration splashed on the employee. The employee sustained second-degree chemical burns to the left thigh and third-degree burns to right thigh…. Membership Required You must be a member to access this content.View Membership LevelsAlready...
WorkSafeBC launched a three (3) phase ammonia inspection initiative after three (3) workers died in an ammonia leak at an ice skating rink in October 2017. Working with Technical Safety BC, WorkSafeBC inspected 228 ice rinks, curling rinks, and recreational rinks during phase one of the initiative. Of those, 181 used ammonia-based refrigeration systems and 1,108 orders…...
SAFTENG members can get an update to EPA’s Ammonia Refrigeration General Duty Clause (GDC) Pilot Project from Janet Bowen, EPA Region 1, presentation. This program is slated to end on September, but ammonia refrigeration was chosen as one of the priority sectors for this GDC enforcement pilot. Mrs. Bown provides us with nice updates on this pilot program and the problems…...
This month’s CCPS Process Safety BEACON is about energy isolation practices in chemical process units and although I personally think they missed the mark on this one, it is a PERFECT EXAMPLE as to why many businesses involved with processing Highly Hazardous Chemicals/Extremely Hazardous Substances do NOT allow for “single valve isolation”, especially when there is NO…...
This incident is a tad dated (2016) but it is a perfect example of how a contractor doing work “adjacent” to a covered process can impact that process. It is also a great opportunity to discuss how to establish the process “battery limits”. I like to call this my “force field” around my process –…...
I recently came across some interesting RMP data from the state of North Carolina (NC), one (1) of the nine (9) states granted delegation of EPA’s authority to implement and enforce the risk management program rule. It is only a very small percentage of RMP covered facilities, but these data and trends may be the…...
As we have discussed here many many times, pressure testing of our primary containment systems for our hazardous materials is an absolute necessity to ensure the integrity of our construction/installation and/or alteration/repair. But these tests come with some serious risks, EVEN HYDROSTATIC TESTING is a very hazardous activity. And as shown in the OSHA investigation…...
If you stay in process safety long enough you will see some scary stuff! It seems that “piping inspections” are become the norm these days, which after only 27 years of OSHA’s PSM standard being around I guess it is “about damn time!”. Having grown up in the chemical industry, MI inspections were a way…...
