Chemical Process Safety (PSM/RMP)

OSHA memo on RAGAGEP in Process Safety Management Enforcement

MEMORANDUM FOR: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH: DOROTHY DOUGHERTYDeputy Assistant Secretary FROM: THOMAS GALASSI DirectorDirectorate of Enforcement Programs SUBJECT: RAGAGEP in Process Safety Management Enforcement This memorandum provides guidance on the enforcement of the Process Safety Management (PSM) Standard’s recognized and generally accepted good engineering practices (RAGAGEP) requirements, including how to interpret “shall” …...

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Another atmospheric tank over-flow incident with a flammable liquid (CSB)

Today the US Chemical Safety Board released a DRAFT report on a 2009 Explosion and Fire at a petroleum terminal facility.  So far, the CSB has identified “Inadequate Management of Gasoline Storage Tank Overfill Hazard” as the root cause of this accident.  I can still remember the 2005 Buncefield incident that very closely mirrors this…...

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Example Contractor Work Permit

CLICK HERE (doc) for one of the Contractor Work Permit written program that I used during my time as a Safety Manager in the chemical industry. CLICK HERE (pdf) for the Work Permit… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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EO 13650 Actions to Improve Chemical Facility Safety and Security (Working Group Update)

June 2015 marks the one-year anniversary of EO 13650 – Actions to Improve Chemical Facility Safety and Security – A Shared Commitment: Report for the President. The EO Working Group has released a fact sheet on the accomplishments to date on improving chemical facility safety and security since the publishing of the Report to the…...

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ASSE 2015 Presentation and PSM Inspection Data (2/27/2014 to 3/30/2015)

This week I am teaming up with my friend and safety colleague Jonathan Zimmerman at the 2015 ASSE Conference.  I have uploaded our presentation, as well as the PSM Inspection Data that was so generously provided by some other friends who I can not mention publicly (but you know who you are and THANKS a…...

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Executive Order 13650 – Improving Chemical Facility Safety and Security Webinar Listening Session

Date: Friday, June 19, 2015Time: 1:00 pm – 2:30 pm EDTPlease join us for a webinar on Executive Order: Improving Chemical Facility Safety and Security. This webinar will provide an update on actions items since the June 6, 2014, release of “Executive Order 13650: Actions to Improve Chemical Facility Safety and Security.Webinar Registration:  Please email…...

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Example Car Seal Program

For the past several weeks, I have worked with clients who have realized they needed a Car Seal Program to comply with their pressure vessel RAGAGEP (e.g., ASME Section VIII) as it applied to their relief valve design basis.  I have updated the written program for SAFTENG members.  One of the clients utilizes “tag-out,” so the…...

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A Process Hazards Analysis is NOT an “engineering review” – Part II

Earlier this week I struck a nerve with many of you; mostly positive comments and agreement and I appreciate all your support.  I received some challenges and I appreciate those as well as they push me to become a better safety professional.  Most of the challenges were of the position “it is not wrong/improper” to…...

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A Process Hazards Analysis is NOT an “engineering review”

There is a method to OSHA’s madness in PSM (as well as EPA’s with regards to RMP) when it comes to conducting a Process Hazard Analysis (PHA).  Unfortunately too many facilities have been duped into believing that the effort they put forward into what they called a PHA was quite frankly a waste of time. …...

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Pipe labeling by way of ASME A13.1

A review of our 2013/2014 audits showed that pipe labeling is a problem across all industries and all types of hazardous materials. Out of 39 audits, 19 had issues with pipe labeling, with the vast majority of those issues being “labeling not meeting a RAGAGEP or company standard.”  During audits, it all boils down to…...

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