I was recently reminded of how so many in process safety struggle to see their process(s) thru different lenses based on the piping’s life cycles. Using ASME B31.3 and 31.5, we see that these codes (e.g. RAGAGEPs) are design and build piping standards. Looking at API 570 series we see these are codes (RAGAGEPs) for […]
In OSHA’s 2018 fiscal year it conducted 28 inspections at Refrigerated Warehouses and Cold Storage facilities. This resulted in 84 citations being issued, totaling $426,241. The Top 10 Standards OSHA found issues with were:
This week EPA updated the RMP Rule, which includes all of the amendments that had been delayed. One such amendment was to §68.96 Emergency response exercises where EPA now requires facilities with Program 2 and 3 covered process to conduct some “official” actions in regards to “table-top” and “field exercises”. In this article I will break down
The Environmental Protection Agency (EPA) announced today (12/4/2018) that the amendments to the Risk Management Program under the Clean Air Act put forward in a final rule published in the Federal Register on January 13, 2017 are now in effect. The rule amending 40 CFR part 68, published at 82 FR 4594 (January 13, 2017)
Inherently safer practices are an approach to the design of safer chemical processes with clear potential benefits related to safety, health, and the environment. Following are strategies for achieving an inherently safer process:
I have discussed this many many times with clients over the years, as most have difficulty seeing the logical transition from each phase to the higher level of response. So in this article, I will attempt to show the transition as to when we leave PSM/RMP operating procedures to our EAP and if necessary how
This is a recording of a live session that took place on October 30, 2018. The session was intended for refrigeration contractors & mechanics. The following was covered: Key findings of the Fernie Investigation Recommendations from the Investigation that pertain to owners/operators of ammonia refrigeration plants Open question & answer period
This is a recording of a live session that took place on October 30, 2018. The session was intended for refrigeration contractors & mechanics. The following was covered: Key findings of the Fernie Investigation Recommendations from the Investigation that pertain to owners/operators of ammonia refrigeration plants Open question & answer period
OSHA’s and EPA’s process safety standards require the host facility to “explain to contract employers the applicable provisions of the emergency action plan” (1910.119(h)(2)(iii), which is a REQUIRED PLAN for all facilities with a PSM/RMP covered process. But what does OSHA/EPA mean when they use the phrase “applicable provisions of the emergency action plan“? We
Simply put, “corrosion allowance” is an extra amount of thickness added to the thickness of the pipe/vessel wall based on the expected exposure the pipe/vessel may see during its lifespan. Typically, my experience has been that corrosion allowance has a safety factor equivalent to 2 when the vessel/pipe was knowingly going to be exposed to
If you have been too busy to read the latest edition of NFPA 2112 (e.g. 2018), oh boy have you missed some fun reading. For the most part, the standard is the same, but there are some significant nuggets that stand to impact a lot of facilities, especially those who allow “emblems” on their FRC.
I came across an interesting “Annual HAZMAT Report” for New York City and in it was a listing of the RMP facilities within the cities boundaries. Who would have ever guessed there were 366 RMP facilities within NYC borders!
