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
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
