Chemical Process Safety (PSM/RMP)

4C HSE Conference PSM Presentation

An old boss from my GE Plastics days is presenting at the 4C HSE Conference in San Antonio, TX on April 3, 2018.  His presentation is titled:  Forget About the Feds, States are Moving on Expanded PSM/RMP Rules – Is it California Dreamin’ or a Glimpse into the Future of PSM/RMP Rulemaking?  Dan is one of my…...

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FM Global offers a HOT WORK PERMIT APP

Improperly managed hot work has proven to be a leading cause of loss each year. Don’t get burned by it.  With the FM Global Hot Work Permit app, you can efficiently conduct, track and monitor hot work from the palm of your hand, while maintaining consistency with FM Global data sheets and engineering standards.  The Hot Work…...

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When your hot gas defrost just isn’t get’n her done!

Just when you think you have seen it all, some business steps up and surprises me once again!  This time we visit a refrigeration process at a cold storage facility that specialized in fruit juice concentrates.  This team did not like to “defrost” their evaporators the traditional way using hot gas; so much that they preferred to…...

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Returning to Service after Line Break/Process Opening GONE BAD (SO2 Valve)

At 12:15 a.m. on June 21, 2017, an employee was unlocking manual valves of a digester. As the valves were loosened, sulfur dioxide leaked from the drain and contacted the employee’s face. The employee sustained irritation to his lungs and eyes, which he was hospitalized and received treatment…. Membership Required You must be a member...

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Ohio Environmental Protection Agency’s Business Impact Analysis on OAC Chapter 3745-104, “Accidental Releases Prevention Program” (RMP)

The State of Ohio’s EPA performed “Business Impact Analysis” on their version of the Risk Management Plan, as part of an Ohio requirement.  The Ohio EPA RMP rules, which are consistent with federal requirements, became effective August 13, 1999. Ohio EPA received “Delegation of Authority” for the Accidental Release Prevention Program, or Risk Management Plan (RMP) program, effective…...

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Federal EPA considering a “new fee” for facilities under the RMP and SPCC rules

For those of us who live and work in states that have Risk Management Plan enforcement delegation (like Ohio), Risk Management Plan “fees” are nothing new.  But now, Federal EPA is considering charging a “Fee” for those facilities that submit an RMP AND are under federal EPA RMP enforcement. There is no mention if this…...

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FM Global’s NEW Data Sheet shares Loss Histories related to Ammonia Refrigeration Processes

FM Global, my absolute favorite source of RELIABLE and FREE safety information has published a new Data Sheet titled 7-13 Mechanical Refrigeration.  This data sheet and hundreds more are available for FREE (after a very brief registration) to anyone.  A truly MUST have for any safety professional working in an industrial environment!  In their new Data Sheet, 7-13 Mechanical…...

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Ohio’s new Mechanical Refrigeration Code (based on IFC 2015)

In December 2017, the state of Ohio adopted it’s new “Fire Code” which happens to be a revised version of the 2015 International Fire Code.  In November I posted a “heads-up” article about the “proposed” changes to new AMMONIA REFRIGERATION processes built in Ohio after 12/15/2017 and how their relief system(s) will be allowed to…...

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Documenting the “isolation” of a Permit-Required Confined Space

To continue with my series of LOTO articles this month, I want to discuss how 1910.147 plays into our efforts to enter a Permit-Required Confined Space (PRCS).  Way too many PRCS entry permits have the basic check-the-box statement “All energy sources isolated – YES/NO.”  What the heck is that supposed to meet?  Do our “machine…...

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OSHA’s General Duty Clause and RV’s “discharging to a safe location”

Anyone who has worked with ASME/API pressure vessel codes knows the basic language used to describe Relief Valve (RV) discharge locations… “discharge to a safe location”.  This requirement applies to ALL relief devices on all types of equipment and although OSHA does not have a specific standard on relief devices and their design, they will use…...

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Process Safety Training – April 2-6, 2018

A local client has requested another 40-hr Process Safety Management course and we have scheduled it for the first week of April 2018.  The course will be at: Sugar Creek Packing Company 2600 N James H McGee Blvd Dayton, OH 45417 NOTE: this is the same location that held the “Safety for PSM/RMP Managers” course. Time: …...

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ASME B31.3 Pressure Testing and Leak Testing Requirements for Process Piping

Last year I broke down the pressure and leak test requirements found in ASME B31.5 for those of you in the Ammonia Refrigeration industry, and at the time, I promised I would do the same for those of you that use ASME B31.3 in all the other process industries. And as I got busy with…...

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