Chemical Process Safety (PSM/RMP)

The RMP Amendments are NOW EFFECTIVE as of TODAY

The Environmental Protection Agency (EPA) announced today (12/4/2018) that the amendments to the Risk Management Program under the Clean Air Act put forward in a final rule published in the Federal Register on January 13, 2017 are now in effect. The rule amending 40 CFR part 68, published at 82 FR 4594 (January 13, 2017)…...

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What are inherently safer practices?

Inherently safer practices are an approach to the design of safer chemical processes with clear potential benefits related to safety, health, and the environment. Following are strategies for achieving an inherently safer process: … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Moving from PSM/RMP Operating Procedures to Emergency Action Plan (EAP) to Emergency Response Plan (ERP)

I have discussed this many many times with clients over the years, as most have difficulty seeing the logical transition from each phase to the higher level of response. So in this article, I will attempt to show the transition as to when we leave PSM/RMP operating procedures to our EAP and if necessary how…...

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Fernie Investigation- Findings & Recommendations for Refrigeration Contractors/Mechanics (Video Presentation)

This is a recording of a live session that took place on October 30, 2018. The session was intended for refrigeration contractors & mechanics. The following was covered: Key findings of the Fernie Investigation Recommendations from the Investigation that pertain to owners/operators of ammonia refrigeration plants Open question & answer period… Membership Required You must...

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Fernie Investigation- Findings & Recommendations for Refrigeration Contractors/Mechanics (Video Presentation)

This is a recording of a live session that took place on October 30, 2018. The session was intended for refrigeration contractors & mechanics. The following was covered: Key findings of the Fernie Investigation Recommendations from the Investigation that pertain to owners/operators of ammonia refrigeration plants Open question & answer period… Membership Required You must...

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What are “applicable provisions of the emergency action plan” for contractors working at a PSM/RMP covered facility?

OSHA’s and EPA’s process safety standards require the host facility to “explain to contract employers the applicable provisions of the emergency action plan” (1910.119(h)(2)(iii), which is a REQUIRED PLAN for all facilities with a PSM/RMP covered process. But what does OSHA/EPA mean when they use the phrase “applicable provisions of the emergency action plan“? We…...

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What is “corrosion allowance” and why should I care about it?

Simply put, “corrosion allowance” is an extra amount of thickness added to the thickness of the pipe/vessel wall based on the expected exposure the pipe/vessel may see during its lifespan. Typically, my experience has been that corrosion allowance has a safety factor equivalent to 2 when the vessel/pipe was knowingly going to be exposed to…...

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Flame-Resistant Clothing and emblems (and reflective striping) on the garments (Size now matters!)

If you have been too busy to read the latest edition of NFPA 2112 (e.g. 2018), oh boy have you missed some fun reading.  For the most part, the standard is the same, but there are some significant nuggets that stand to impact a lot of facilities, especially those who allow “emblems” on their FRC. …...

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NYC RMPs

I came across an interesting “Annual HAZMAT Report” for New York City and in it was a listing of the RMP facilities within the cities boundaries.  Who would have ever guessed there were 366 RMP facilities within NYC borders!… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log...

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EPA’s 2017 RMP Amendments Compliance Obligations

Due to a September court decision that vacated the RMP Amendments effective date delay, and the court’s expedited issuance of its mandate, the FINAL RMP AMENDMENTS RULE IS NOW IN EFFECT. Because the 2017 rule contains a schedule of compliance dates for many of the major provisions, the issuance of the mandate does NOT create current compliance obligations…...

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Fatal Explosion – catalyst Raney nickel was exposed to air during cleaning

NOTE: the text below is a translation from Chinese to English At about 13:49 on May 3, 2018, a catalyst explosion occurred in the hydrogenation reactor of No. 1 hydrogenation reactor of a Pharmaceutical facility causing one death and an immediate economic loss of 1.446 million yuan ($216,061,320 USD).  According to the “Safety Production Law of…...

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