Chemical Process Safety (PSM/RMP)

EPA RMP Amendment(s) UPDATE (May 2018)

On May 17, 2018, EPA’s Administrator signed a proposed rule requesting public comment on several proposed changes to the final RMP Amendments issued on January 13, 2017. EPA is proposing to rescind amendments relating to: safer technology and alternatives analyses, third-party audits, incident investigations, information availability, and several other minor regulatory changes EPA is also…...

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Which ASME B31 Piping RAGAGEP will apply to my process piping?

It is the owner’s responsibility to select the applicable code section(s) that apply to the proposed piping installation. Factors to be considered in this decision include: scopes of the code sections; jurisdictional requirements; and the applicability of other codes and standards Each B31 code section is intended to be applied as a whole to a…...

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OSHA’S revised Process Safety Management “Retail Exemption” Enforcement Policy (2018)

  MEMORANDUM FOR: REGIONAL ADMINISTRATORS THROUGH: RICHARD MENDELSON, Acting Deputy Assistant Secretary FROM: THOMAS GALASSI, Director Directorate of Enforcement Programs SUBJECT: Process Safety Management Retail Exemption Enforcement Policy… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Top 10 errors using Flame-Resistant Clothing (FRC) for flash fire protection

Using NFPA 2113 as our RAGAGEP, these items are by far the most common errors we find in our work when FRC is worn in flammable/HAZLOCs work areas:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Changes to facilities that affect a covered process (1910.119(l)(1)

Recently I came across another real-life example of a “change to facilities that affect a covered process” that was missed in the MOC process and created a significant hazard to the flammable liquids processing area.  The change was a new pallet-jack for the process area, and when it came time to purchase the new one,…...

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Diesel Tank Hot Work Incident Investigation Report

This tank fire incident is a MUST READ for all SAFTENG members who are in process safety and industrial safety who manage bulk tanks containing hazardous materials.  The learnings from this incident investigation are too many to mention,  but the investigation got into: Corporate Strategy and Commitment to Safety & Operational Excellence Contractors Engagement Training…...

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National Board’s position on “intervening stop valves” in Relief systems

In 2017, the NBIC was restructured into four (4) parts, adding a new Part 4, Pressure Relief Devices. This purpose of this restructuring was to provide one distinct integrated part for pressure relief devices compiled from all PRD information referenced in Part 1, Installation; Part 2, Inspection; and Part 3, Repairs and Alterations.  And in…...

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Understanding an NH3 Refrigeration “Emergency Pressure Control System”

An “Emergency Pressure Control System” has been a requirement in the IFC and IMC for several iterations of these codes, and yet it can be a very confusing requirement as they are not found in the vast majority of mechanical refrigeration systems using Anhydrous Ammonia as the refrigerant.  Part of the problem may lie in…...

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Thoughts on our Ammonia Process Diffuser Tank’s Mechanical Integrity

Ammonia refrigeration “diffuser tanks” have been around since the early 1990’s when the Uniform Fire Code (UFC) began requiring them. That means some of these tanks will be due for their Mechanical Integrity Inspection and this is when most facilities will realize that the process design does not lend itself for a safe means to…...

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Is a NH3 discharge to a water diffusion system a “reportable release”

4/20/2018 UPDATE:  To further this discussion… consider a diffuser tank is 95% effective (Source: IIAR Technical Paper), meaning that 5% of NH3 would theoretically make it to the atm. WHEN that 5% is greater than 100 pounds, you have a REPORTABLE RELEASE.  Using an actual “oil separator” at a client, the RV has a 0.75″…...

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Mechanical Integrity for your Anhydrous Ammonia Hose(s)

The Association for Rubber Products Manufacturers (ARPM) is an organization that was started in 2010 after elastomer products company executives belonging to the RMA mutually agreed that a stand-alone association was needed for codes/standards.  Those of us in the process safety field are all too familiar with the RMA and ARPM, as these organizations write…...

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How often are you pressure testing your Bulk Unloading/Loading Hoses?

Almost every manufacturing facility that handles a hazardous material will utilize hoses in their handling of the material.  And one of the biggest risk any facility will manage is the BULK UNLOADING/LOADING of their HAZARDOUS MATERIALS.  Whether the hazardous material is a PSM/RMP covered chemical or just a good ole fashion HAZMAT, the integrity of…...

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