Chemical Process Safety (PSM/RMP)

LPG leak at flange during Start-Up (DMIR)

An operator at a liquefied petroleum gas (LPG) processing facility heard a loud noise coming from an area of the plant during start-up, following significant maintenance works. The operator identified that high pressure, flammable natural gas was being released to the atmosphere from a localized point beneath the insulation of process equipment. The Department of…...

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Shelter-In-Place means a RMP Update is due in 6-months

Recently a facility had an NH3 release via an RV and in the spirit of “doing it right” made all the necessary calls, including notifying their local FD.  The FD arrived, although it was not required as the facility response team had matters under control before their arrival, the FD felt it was necessary to…...

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Process Operators and “Emergency Response”

Employees such as chemical process operators may be required to shut down processes, close emergency valves and otherwise secure operations that are not in the hot zone or danger area before evacuating in the event of an emergency. (See 29 CFR 1910.38(a)(2)(ii).) These procedures need to be delineated carefully, and employees must be trained to…...

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WorkSafeBC Ammonia Inspection initiative Update (June 2018)

From the WorkSafeBC annual report… In 2017, following work-related deaths at an ice rink, we utilized the Risk Analysis Unit’s research on ammonia exposure to launch a three-phased province-wide inspection initiative focusing on ammonia exposure to ensure that owners and employers of facilities using ammonia are correctly managing the risks associated with the toxic gas…....

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OSHA and “No. 54 drill-size openings” (Anhydrous Ammonia)

Have you ever wondered what a “No. 54 drill-size Opening” is?  This is a phrase used in OSHA’s 1910.111, Storage and handling of anhydrous ammonia.  In simple terms, OSHA has established that if the potential leak is through an opening of No. 54 drill-size or smaller then, the opening need not be protected by an excess-flow valve. …...

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Should a PRD header/manifold system have “intervening valves”?

This is a topic that is near and dear to me, as it is one I learned very early on in my career as a means to safely perform PRD work on an RV or RD that is connected to a header/manifold.  Although this design MUST be adequately done AND must be managed very tightly,…...

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Details matter in our SOPs/SWPs

This is a classic.  Details matter, contrary to what many want to claim about safety plans, programs, practices, and operating and maintenance procedures. The fact is, there MUST be a balance between details and length and complexity.  Some jobs will need a 10-page procedure, and some will need a half-page.  The idea that shorter is…...

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Fiscal Year 2018 U.S. Chemical Safety and Hazard Investigation Board Management Challenges

The CSB faces two management challenges that, if not addressed, may seriously impede the agency’s ability to achieve its mission efficiently and effectively.   Based on our continuous audit work, the EPA OIG has identified two management challenges for the CSB that were not in the fiscal year 2017 report: the lack of authority that…...

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Scissor Lift causes NH3 leak and serious chemical burns and severe respiratory damage

Here is an unfortunate incident that draws our attention to operating elevating equipment inside refrigerated spaces.  This incident also demonstrates the increased hazards to workers working within these elevated devices, as their means of egress, should there be a chemical release, is GREATLY compromised. Lastly, we should NOT lose sight of the fact that this…...

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Why I no longer list “Relief System” as a PREVENTION Safe Gaurd in most of my “HIGH PRESSURE” scenario(s)

For years, PHA’s seemed to always list vessel “relief systems” as a “safeguard” for ALL the HIGH-PRESSURE scenarios involving the vessel.  In this article I want to challenge this practice; but to be up front, if you were to look at all my PHA’s I was guilty as sin for doing this very thing.  But…...

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