Chemical Process Safety (PSM/RMP)

Technical Safety BC Workshop pinpoints two factors behind ammonia releases

Technical Safety BC conducted an ammonia release fault tree workshop to identify potential causes of ammonia releases from industrial refrigeration systems used in arenas and food storage facilities.  The workshop is part of a Technical Safety BC project meant to detect and mitigate emerging and known technical safety risks in the province. The project used the…...

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Can compressed air be used for pressure testing refrigerant piping?

As most process safety professionals know, pressure testing and leak testing piping systems is an absolutely critical function of process safety efforts.  And I am happy to say, the number of facilities that have begun pressure testing and leak testing their piping has grown by leaps and bounds since the passage of OSHA’s PSM and…...

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BSEE Safety Alert – Fired Vessel Hazards Identified in Risk-Based Inspections

The Bureau of Safety and Environmental Enforcement (BSEE) recently conducted a review of recent compliance and incident data to identify safety trends throughout the Gulf of Mexico. The analysis pointed to a potential risk associated with fired vessels. From January 2016 to May 2018, 17 fired vessel incidents were reported to BSEE by 12 unique…...

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EPA releases the 2017 RMP Accidents

This week the EPA released an EXCEL spreadsheet that lists all the “RMP Accidents” that occurred in 2017.  I noticed a couple of key items: Not sure where they obtained the data, as many of the incidents listed did not rise to the level of a “5-year Accident History” incident,  but are shown in this data…...

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Leave the politics out of my Process Safety!

As we approach the mid-term elections in November there is a significant push to try and paint President Trump as some kind of worker and community killer.  These accounts are being pushed by major media outlets and even more, sadly some of the Occupational Publications are following suit.  Just tonight, BLR posted this article “House Bill would…...

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OSHRC differs on what constitutes RAGAGEP

A petroleum refinery was inspected by OSHA as part of its Refinery National Emphasis Program.  A team of compliance officers and industrial hygienists from the Occupational Safety and Health Administration inspected the refinery from September 10 through December 18, 2009. On March 8, 2010, OSHA issued three citations to Respondents, two of which were settled…...

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The difference between and “inspector” and “examiner” (ASME B31.3)

Under ASME B31.3 (Process Piping), the roels and requirements for an Examiner are distinctly different from those for an [Owner’s] Inspector. While the Inspector represents the owner and audits the work, the Examiner represents the manufacturer, fabricator, or erector and is the person actually performing the quality control examinations—including visual inspection. Because ASME B31.3 classifies…...

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Is EPA seeking to modify the List of Regulated RMP Substances?

The EPA is planning to submit an Information Collection Request (ICR), “Risk Management Program Requirements and Petitions to Modify the List of Regulated Substances under section 112(r) of the Clean Air Act (CAA)”, EPA ICR No. 1656.16, OMB Control No. 2050-0144 to the Office of Management and Budget (OMB) for review and approval in accordance…...

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UPDATE on Seafood Plant NH3 Fatality (New Scene Pics)

The fatal release was from the bottom of the “pilot receiver” as shown below: NOTE: SAFTENG Members see the previous post for investigation details and regulatory citations…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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EPA RMP Amendment Dates (as of 9/14/2018)

Based on the most recent court ruling and directions from EPA, here are the DUE DATES for the RMP Amendments as of today (note – courts could change this once again!)…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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A deeper look into OSHA’s PSM vs. EPA RMP

Tried to summarize some of the key differences between EPA’s Risk Management Plan and OSHA’s PSM requirements and even threw in some CFATS info.  Let’s start with EPA’s most recent numbers for a breakdown of the RMP Sites as of 2018 …… Membership Required You must be a member to access this content.View Membership LevelsAlready...

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