A recent story in my local news was regarding changes to traffic patterns made to the 44th most dangerous intersection in OH. A 2018 traffic study showed there had been 114 crashes at the intersection over the previous four (4) years; 40% of those resulted in an injury. The state tried just about every administrative…...
CHANGE… to improve safety (Administrative vs Engineering Controls) Read More »
I see far more damage to atmospheric storage tanks from vacuums than I do from over-pressure events. In almost every case, the tank had undergone a “change” that created the conditions for a vacuum to occur. And once we have a pressure differential with a lower pressure inside the tank than the atmospheric outside the…...
The power of a vacuum (Flammable Liquid Storage Tanks) Read More »
This image from a UK HSE publication may be the best image I have seen on “process safety” and Basic Process Controls Systems (BPCS). It shows how we PREVENT “overfill” events, also known as a Loss of Primary Containment (LOPC) event in atmospheric storage tanks/vessels. The entire publication is a MUST-read for those who store…...
Basic Process Controls Systems (BPCS) for flammable liquids storage tank(s) Read More »
A worker, 41, sustained a serious head injury and died during a piping pressure test. A pipe had been pressurized for testing, and during the pressure release process, a plate from the pipe system broke free and hit the worker in the head. The MI-OSHA case file is still open…. Membership Required You must be...
Pressure Testing GONE BAD (Fire Protection System) Read More »
Four employees were testing an 8″ chiller pipe with pressure when a piping joint failed and an employee was struck in the shoulder and head by a valve cap. The employee was transported by ambulance to a Hospital…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in...
Pressure Testing GONE BAD (8″ Pipe Failure) Read More »
How many of you have thought these two images would ever have a place in Process Safety? I use them as visual aids when teaching some of my RAGAGEP courses, as they place a mental image that most can grasp into the students’ heads and provide them with a valid engineering metric they can…...
Defining and Quantify when Shut Off Valves are necessary/required Read More »
Have you ever read a RAGAGEP and wished you had been a fly on the wall in the room where a particular requirement was presented and debated amongst the committee members? I have set on my fair share of RAGAGEP committees over the past 20 years and in almost all of muy experiences, when someone…...
What to do when my RAGAGEPs conflict (CGA 2.1, 5.8.2.1) Read More »
As we continue to “dumb down” RAGAGEPs to take away OSHA/EPA’s ability to cite fundamental engineering failures found in processes handling HHC/EHS, the issue of “conflicting requirements” continues to be troubling. As my Anhydrous Ammonia clients learned firsthand last year, with the 7th edition of CGA 2.1, the RAGAGEP has some NEW requirements for pressure…...
What to do when my RAGAGEPs conflict (CGA 2.1, 5.6.10 vs. B31.3, 345.5) Read More »
Both OSHA and EPA require PSM/RMP facilities to include procedures for “responding to small releases” in their Emergency Action Plans 1910.119(n) Emergency planning and response The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan shall…...
Responding to “small releases” Read More »
A loss of containment and subsequent release of fluids can cause adverse consequences (i.e., impact safety, health, and environment, cause production losses, andincur maintenance and reconstruction costs). The risk analysis should consider the nature of the hazards and ensure that appropriate factors are considered for the equipment items being assessed. Flammable Events (Fire and Explosion)…...
Understanding our LOPC Flammable and Toxic Risks Read More »
29 CFR 1910.119(f)(1) The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
OSHA issues Car-Seal citations (Relief Protection System) Read More »
In process safety circles, the word “remote” is found in several codes/standards. In OSHA’s Process Safety Management standard, we find it used in the Normally Unoccupied and Remote Facility (NURF) exemption (1910.119(a)(2)(iii). OSHA did us a favor by officially defining this phrase; however, they have never QUANTIFIED it. Normally unoccupied remote facility means a facility…...
Defining and Quantifying the term “Remote” Read More »
