Scenario 1: The first scenario you described has the following attributes: Your firm is engaged in the design and construction of a manufacturing (processing) facility which includes OSHA Category 2, 3, and 4 flammable liquids as raw materials and processing intermediates. The Food and Drug Administration and countries in Europe, the Middle East, and Africa…...
In my work and travels, I have the chance to come across such interesting situations and this one stands to cause quite the stir in some food plants. The use of a “special solution” that is made up of Acetic Acid (64-19-7), Hydrogen Peroxide (7722-84-1), and Peracetic Acid (79-21-1) to “treat” poultry for food containment…...
U.S. EPA New England has developed this document (pdf) to assist ice rink owners and operators with ammonia refrigeration systems in communicating effectively with their employees, contractors, vendors, and customers about ammonia refrigeration safety. Helping facilities to minimize the risk of potential chemical releases, such as an accidental release of ammonia at a refrigeration facility, is a…...
How much do you utilize your Management of Change (MOC) tool? Usually, when the acronym MOC is even whispered, many people begin to roll their eyes, sigh, and in some cases become physically angry. This is one of the mysteries I hope to solve before my retirement – why would anyone dislike a tool that is…...
A couple of weeks ago EPA met the court’s decision by posting the amended RMP rule on the CFR. This meant that those amendments that had dates that had come due were in full play. But on May 30, 2018, EPA proposed changes to the final RMP Amendments rule issued on January 13, 2017. EPA…...
If I had a dime for everytime someone says to me… “where do you come up with all this sh_t?” during our deep discussions on process safety topics. And whenever I do my 5-day Process Safety course we seem to always get deep into the “process safety weeds” and one topic that many students are…...
Yes, as I posted a couple of weeks ago, the RMP Amendments are now in effect (at least those with compliances dates that have passed – some have dates further out). One such requirement that seems to be causing a stir is “3rd Party Audits” for Program 2 and 3 Level RMP processes (e.g. 68.59…...
UPDATE: Earlier this year I posted a news account of an NH3 release in Cincinnati because of statements from a VP of the company stating an “explosion had occured”. I have since learned that yes it was an “explosion”, but not one involving fire as so many think of when they hear that word. From…...
Inspection of buried process piping is different from above ground process piping because significant external deterioration can be caused by corrosive soil conditions and the inspection is much more difficult due to the inaccessibility of the piping. However, as difficult as it may be, buried piping MUST be inspected to determine its external surface condition…....
I was recently reminded of how so many in process safety struggle to see their process(s) thru different lenses based on the piping’s life cycles. Using ASME B31.3 and 31.5, we see that these codes (e.g. RAGAGEPs) are design and build piping standards. Looking at API 570 series we see these are codes (RAGAGEPs) for…...
In OSHA’s 2018 fiscal year it conducted 28 inspections at Refrigerated Warehouses and Cold Storage facilities. This resulted in 84 citations being issued, totaling $426,241. The Top 10 Standards OSHA found issues with were:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
This week EPA updated the RMP Rule, which includes all of the amendments that had been delayed. One such amendment was to §68.96 Emergency response exercises where EPA now requires facilities with Program 2 and 3 covered process to conduct some “official” actions in regards to “table-top” and “field exercises”. In this article I will break down…...
