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
There may come a time that we need to pressure test one of our pressure vessels after a repair or alteration and our FIRST CHOICE of methods to use should be Hydrostatic as it is MUCH SAFER than pneumatic. However, in some cases, we may NOT be able to perform a hydrostatic test for a
Some processes have a relief system that includes a rupture disk below the relief valve. This is done for several reasons, but the two most common reasons are: The process is corrosive and can cause issues with the Relief Valve leading to failures and a shortened life span The process contains a Category M fluid and any leakage, ever
One of the recent amendments of EPA’s RMP rule impacted our Incident Investigation procedures/practices and most likely any report forms we had been using for years and years. The RMP and PSM Incident Investigation elements used to be very similar and thus most of us used the same procedure/practices and forms when trying to comply
The state of NJ has developed a Toxic Catastrophe Prevention Act (TCPA) Program Update intended to assist regulated TCPA facilities in understanding how they are impacted by the January 13, 2017, amendments to EPA’s RMP Rule, 40 CFR Part 68. The table indicated the effective dates of the amendments, which provisions are incorporated by the
Many of us in the PSM/RMP arena use NFPA 51B as our Hot Work Safety Standard, rather than 1910.252(a) and with that said I thought I should update us on NFPA’s 2019 edition of 51B which includes several key improvements. Probably the biggest changes from the 2014 edition are: the term FIRE WATCH is now officially
One phrase that drives me crazy while working with my friends in the Ammonia Refrigeration industry is, “Come on, Bryan; we’re not a refinery or chemical plant; that is unnecessary here.” For example, recently, we were asked to aid in an investigation into a reportable release from a PSM/RMP-covered process, and during our review of
