Chemical Process Safety (PSM/RMP)

WorkSafe BC – Ammonia in Refrigeration Systems (Revised 3/2018)

Last month, March 2018, WorkSafe BC revised their “Ammonia in Refrigeration Systems” manual.  This manual describes the hazards of ammonia and how to prevent and control exposure. It lets you know your responsibilities as an employer and shows you how to prepare for emergencies and investigate ammonia releases to help prevent future accidents…. Membership Required...

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CFATS data update

Current Statistics To date, DHS has received more than 88,258 Top-Screen submissions from more than 40,000 unique facilities. Of these, the CFATS program currently covers 3,441 facilities. These high-risk facilities are divided into four tiers, with Tier 1 facilities posing the highest security risk. CFATS Activities It is important to note that this regulatory program…...

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Are your fire hydrants in your Mechanical Integrity Inspection/Testing program?

Is your fire water is a “protection/mitigation” safeguard in your Process Safety program?  Most covered processes, whether toxic or flammable, will utilize firewater as a “critical utility” to help protect/mitigate a release and/or fire from the process.  When this is the case, our fire water system (reservoir(s), pump(s), fire water piping, hydrants, monitor nozzles, etc.)…...

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Protecting your fire hydrants and connections per “code”

Recently we were performing an audit at a clients facility in which we had done the previous 3-year PSM/RMP audit.  And during that prior audit, we observed a damaged hydrant that had been out of service for several months, and we came across another instance where the facility identified another hydrant that was damaged; both…...

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How many RMPs do you have vs. How many processes you report in your single RMP

This topic is a bit off, but for some reason, this issue is trending in our RMP/PSM audit findings.  We have been finding this since we began performing RMP audits in the 2002-2003 time frame, but the numbers are trending up.  Now, this is NOT about a “hazardous condition,” but in almost all our cases,…...

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Relief Valve Testing and the National Board

Recently I posted an article about the IIAR’s new Maintenance Standard that was going to allow bench testing of a “sampling” of our Relief Valves (RVs) as an alternative to the 5-year cycle.  I have written numerous times about this practice, but I could never compete with the National Board’s article(s) on the topic.  Their…...

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EPA updates the RISK MANAGEMENT PLAN RMP*eSUBMIT USER’S MANUAL

The Federal EPA just updated their RMP User Manual.  This is the go-to manual to find all the answers to your RMP submittal questions when using RMP eSubmit Software.  The manual “unofficially” also provides much insight into all the submittal data you are being asked to provide.  It even explains how the WCS and ARS…...

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OSHA, along with EPA and DHS, make up the Chemical Facility Security and Safety Working Group

Sen. Chuck Schumer announced today that OSHA, the Environment Protection Agency (EPA), and Homeland Security (DHS) have agreed to create new protocols requiring notifications and coordination with local governments & emergency services when a company is cited with serious violations in wake of the deadly chemical explosion and fire at a cosmetic factory.  In January,…...

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Can I install a PSV in a horizontal position?

We visit this topic again and again, the short answer is NO! According to ASME Section VIII, Division 1 (UG-135) and API RP 520, Pressure Safety Valves (PSVs) must be installed in a vertical position with the spindle (stem) oriented upright. Installing a valve horizontally is considered a significant deviation from engineering standards and can…...

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IFC’s Section 606.8 Refrigerant detector, alarm signals and “approved location(s)”

In the International Fire Code, Section 606 – Mechanical Refrigeration has two distinct requirements regarding the refrigerant detector(s) and their alarm signal and in both requirements, the phrase “approved location” is used.  In one case, they are talking about the location of the actual refrigerant detector/sensor, and in the other case, they are talking about…...

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Is the IIAR adopting “bench testing” for Relief Valves?

CORRECTION Made 3/21/2018 So I was glad I was sitting down when I started reading the Public Review #2 Draft of IIAR-6, Standard for Inspection, Testing, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems.  Now it’s just a DRAFT version out for public review and comments, but I was so pleased to see TABLE 13.1, Overpressure Protection…...

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WorkSafeBC Ammonia Inspection Initiative update (2/2018)

Between November 20 and December 31, 2017, WorkSafeBC officers conducted the first phase of a three-phase ammonia inspection initiative. Officers inspected ice rinks and recreational facilities that use ammonia as a refrigerant. The focus of the inspections was: risk assessment, exposure control plans, work procedures, emergency response and evacuation plans Of the 223 sites inspected,…...

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