On June 29, 2005, Employee #1 was involved in the following the maintenance activities in the Chloropyridines Complex at the employer’s chemical manufacturing facility. Employee #1 was returning a reactor vessel to service. He was attempting to do a pressure and leak test using chlorine gas. The pipe was supposed to be pressure tested with…...
When we think about process safety, we can think of the analogy of a wild animal inside its cage… as long as the cage holds or we don’t open the door on the cage the wild animal is safely contained. Unfortunately, sometimes the cage was not designed to hold such a powerful animal and believe it…...
Most, unfortunately not all, process safety professionals will agree that doing a “line break” on an actual process pipe containing the PSM/RMP covered chemical (HHC/EHS) falls within 1910.119(f)(4) or 68.69(d). But when it comes to “process hoses”, there remain many application questions. For me, any time the “process” is opened I break the task down…...
At 8:30 p.m. on May 11, 2017, two employees had been welding a pipe assembly and installed it on a chlorine tank. Employee #1 opened a valve to transfer the liquid chlorine from a supply tank into the weigh tank. A flange fitting was not tightened and both employees were sprayed with liquid chlorine. Both…...
The CSB has released its case study titled “Key Lessons for Preventing Inadvertent Mixing During Chemical Unloading Operations,” which examines a mixture of incompatible materials at a Processing Plant that produces distilled spirits and specialty wheat proteins and starches in Atchison, Kansas on October 21, 2016. The mixture resulted in a chemical release containing chlorine…...
WOW, just wow, CF Industries has produced a world-class video from an incident they had back in 2015. You’re in a class on your own when you publically take an incident and turn it into a learning for others to benefit from. The incident involved a failure of a high-pressure flange on a hydrogen process. What they…...
On May 20, 2017, at 11:30 a.m. Employee #1, a refrigeration technician, and a coworker were performing pump down of a live ammonia refrigeration line to make the pipe available for replacement. The two (2) employees had checked the line on the roof with a blower and thinking it was clear, went to the engine…...
This month Koch Agronomic Services (KAS) announced they have developed a “nitrification inhibitor” for their anhydrous ammonia (NH3) fertilizer that will significantly improve nitrogen use efficiency (NUE) to increase crop output while minimizing environmental losses. This is great news for all of us; however, for those at the facilities where this new grade of NH3 is being…...
Ontario’s Engineering Data Sheet 4-04: Anhydrous Ammonia is an excellent source of reliable safety information for the design of and practice of safely handling anhydrous ammonia. It is another example of how we can use information from other agencies around the world to better design, build, operate and maintain processes handling/storing/processing highly hazardous chemicals…. Membership...
As this year comes to a close, I was reminded by a FaceBook post of a common misconception regarding 1910.119(f)(3), which is actually two (2) separate requirements/actions stated in a single paragraph of the standard. The standard states: 1910.119(f)(3) The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including…...
As I have said before, one of EPA’s most cited RMP matters is the lack of “updating the RMP with emergency contact information within a month of the change“. But today, the EPA offered some insight for those who may not have an emergency contact assigned within the month of the change. For me, there are…...
The Ohio EPA RMP Group has posted a CHECKLIST FOR SIMPLE REVALIDATION (pdf) on their RMP Page of thier website. This 6-page checklist appears to be an excellent tool for “revalidating” your Process Hazard Analysis (PHA) every 5-years. You can download their pdf version HERE. SAFTENG members can download a different version by logging in and…...
