UPDATED on 2/6/19, based on feedback from my friend and Refrigeration PSM Extrodinare Brian Chapin over at RCE (A former Partner in Safety). I have shared his analysis and my rebuttal/agreement… By a long shot, these are the top three (3) issues found with Ammonia Refrigeration RMPs: The NH3 is “Liquified by Pressure” – not […]
One of my favorite parts of teaching the 1-day PSM Intro course at ASSE SeminarFest is the vast numbers of students and all of their learnings and experiences being shared. This year was even better than years before – in fact, we had so many side-bar discussions because of the great input from the students
Those in the PSM/RMP world know that the facility is REQUIRED to have an Emergency Action Plan (1910.38) and by virtue of having to comply with 1910.38, we also have to comply with 1910.165 Employee Alarm System. The language in 1910.165 is really vague and causes much confusion when it comes to the emergency alarm
Recently I had a client who made alterations to a pressure vessel (PV) in an ammonia refrigeration process that required the PV to be re-certified. The state where this PV resides is a “coded state”, meaning they have adopted ASME Code for the PVs within the state. So, the contractor making the alterations had scheduled
If API 570 is your facility’s piping inspection/repair RAGAGEP, the battle over “repair requirements” just got easier! A very popular question in PSM/RMP circles has become… “Do we have to make repairs in the same manner as we did the initial install of the pipe?” In other words, what is being asked is… “Can we bypass
In my travels to our friends north of the US border, it is not uncommon to find “used vessels” in service that were never intended to be used that far north and for the record, this occurs in the USA northern states as well. The figure below is one that is used by many to
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
