Question: How may a corporation with multiple facilities regulated under CFATS request the corporate approach and what benefits does this provide the corporation?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
CFATS Corporate Approach (DHS 1/20/15) Read More »
A question I am asked nearly each month is… do I have to have a person dedicated to operating the boiler and is this person restricted from performing any other functions while acting as the “boiler operator”? While I am not a “boiler expert”, most of my clients have industrial size boilers associated with their…...
The U.S. Chemical Safety Board released a safety bulletin intended to inform industries that utilize anhydrous ammonia in bulk refrigeration operations on how to avoid a hazard referred to as hydraulic shock. The safety lessons were derived from an investigation into a 2010 anhydrous ammonia release. The accident occurred before 9:00 am on the morning…...
Anhydrous Ammonia Safety Bulletin – Five Key Lessons to Prevent Hydraulic Shock (CSB) Read More »
Yes. A facility closure may be considered a material modification to a covered facility. In this case, the facility must complete and submit a revised Top-Screen to the Department of Homeland Security (DHS) within 60 days of the material modification (i.e., its closure), in accordance with 6 C.F.R. § 27.210(d), available at http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=5490ca42ba3517c7c9aec9c47cefc750&r=PART&n=6y1.0.1.1.11. When completing…...
Does a facility have an obligation to notify DHS if the facility is closing? Read More »
2/4/2015 UPDATE After many lengthy discussions with engineers and inspectors I have come to the conclusion that although this practice may be permitted by code, albeit by a five-word phrase in an interpretation, most engineers stated they would NOT use a dual stamped vessel unless it was careful analyzed via a PHA or detailed engineering…...
Dual Stamped pressure vessels Read More »
One of the more common omissions in SOPs is the inclusion of all the “safety systems and their functions” involved in the execution of the SOP. In this article, I will use the task of Truck/Railcar Unloading a Flammable Liquid to demonstrate the types of safety systems and their functions that may need to be…...
Safety systems and their functions in our SOPs Read More »
Yes, it is true… 1910.119(g)(2) states “Refresher training shall be provided at least every three years, and more often if necessary…” Please take note that the phrase “at least every” is used preceding the 3-year frequency, as well as OSHA explicitly states “more often if necessary”. In my 20+ years of developing, implementing and managing…...
PSM/RMP Refresher Training Frequency is not a 1,094 day vacation from training! Read More »
This week the WV Attorney General Office (WVAGO) released their investigation report on the 2014 Elk River Chemical spill. This incident caused a mandatory Do-Not-Use (Water) order to be issued and more than 300,000 residents and countless businesses in a nine-county radius were without potable water for nine (9) days. This incident has now been…...
Another MI Lesson to be learned – Tank Integrity Read More »
If I were to do 20 PSM/RMP audits per year with new clients, I estimate that I would have the following debate 15 times! In my Process Safety courses, I have a little fun with the phrase “Upwards and Unobstructed” as I make the class stand and repeat that phrase three times. But somehow/somewhere, this…...
ASME defines “safe location” for PRDs Read More »
PSM/RMP covered process(s) owner’s/operators have the option to manage the integrity of their plant and plan inspection from assessments of the risks of failure. They need to be able to demonstrate that the risk assessment and inspection planning processes are being implemented in an effective and appropriate manner. The aim of this report is to…...
UK’s HSE issues guidance on RBI Maintenance Programs Read More »
With the recent fatal accident involving methyl mercaptan, I thought it would be a good time to remind us of another significant methyl mercaptan accident that claimed the lives of three workers. The recent accident claimed four workers via inhalation/asphyxiation and the one in 2001 involved ignition and the workers died as a result of…...
On December 11, 2014, the U.S. House of Representatives unanimously passed the Senate amendment to H.R. 4007, the Protecting and Securing Chemical Facilities from Terrorist Attacks Act – legislation to reinforce the protection and security of chemical facilities from terrorist attacks. Specifically, the House concurred in the Senate amendment to H.R. 4007 to extend the…...
Congress Passes Legislation to Reinforce Protection and Security of Chemical Facilities Read More »
