Chemical Process Safety (PSM/RMP)

RMP Data by the numbers as of November 2017

I am sorry I am a tad late on this year’s summary, but here are the numbers as they were in the latest database update.  Some surprises here… 12,380 RMPs on file 1,328 RMPs have an accident history 24 RMPs have had a fatal RMP accident 16,598 RMP injuries have occurred at these RMP sites…...

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FM Global is leading the way with revised Hot Work Permit and Fire Watch Requirements

Leave it up to FM Global to lead the way in Hot Work Safety.  I know in my career there has been no other force in hot work safety like FM Global (Formerly Factory Mutual).  And I am guessing that all of these large loss fires in the construction industry these past couple of years…...

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What your piping contractor should provide you for your PSM/RMP piping installation(s)

Over the last 15+ years we have seen great improvements regarding piping installation(s) at PSM/RMP covered processes.  Since 1992 (PSM implementation) these “covered processes” were required to adopt a RAGAGEP for all aspects of their covered process.  ASME has had their B31 series in place for decades and they are the most widely recognized piping…...

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UPDATE on the 40,000 NH3 release in IL in April 2016

As we await word of any regulatory action stemming from the catastrophic release of Anhydrous Ammonia from a truck unloading incident in Stewardson, IL, in April 2016, I did come across an interesting tidbit that I feel should be shouted from the mountain tops.  So often, one side of our profession decries OSHA and EPA’s…...

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Ohio upgrades Hot Work requirements when performing Hot work on flammable and combustible liquid storage tanks

The state of OH is in the process of updating it’s fire code to the 2015 International Fire Code (IFC).  In doing so, the state is upgrading its Hot Work requirements when performing hot work on flammable and combustible liquid storage tanks.  The proposed code will include a new section, Section 3510 Hot work on flammable and…...

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State of Ohio to require NH3 RV Discharge to be thru a destruction system or have an engineering analysis stating otherwise

The state of OH is in the process of updating it’s fire code to the 2015 International Fire Code (IFC).  In doing so, the state is upgrading its Mechanical Refrigeration requirements and one of the upgrades may have an impact on future Ammonia Refrigeration processes that have over 6.6 pounds (3 kg) of ammonia refrigerant, which would include almost…...

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Hydrostatic test or Pneumatic Test… which shall I use on my flammable liquid piping?

The debate rages on in process safety circles as to how one can “pressure test” their piping that was installed using ASME B31 series of RAGAGEPs.  It has always been “the rule” that we use the hydrostatic method UNLESS this method would cause a hazard or purity concern; however, as with most practices we have…...

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Bleeding off NH3 Accident (2017)

At 3:10 p.m. on February 7, 2017, an employee was making preparations to replace the relief valve of 1,000-gallon ammonia (NH3) nurse tank. The incident investigation reported that the tank was empty of liquid NH3. However, it contained approximately 80 psi of vapor pressure. The employee set up a 30-gallon drum that held water and…...

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2017 OSHA PSM activity by Industry Sectors

UPDATED with new data on 5/25/2018…Here is a look at OSHA’s PSM activity in 2017 (October 2016 – September 2017). As you can see, OSHA did 88 PSM inspections and issued 329 citations for a total of $2,032,036 in fines. This is the SETTLED amount and NOT the initial citations. Here is a quick breakdown…...

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How things have changed in the world of RMP Risks… Anhydrous Ammonia

There are 631 fewer RMP covered processes with Anhydrous Ammonia since 2011.  This translates to a reduction of right at 78 million pounds in anhydrous ammonia in reported RMP covered processes. This took anhydrous ammonia from a clear #1 in pounds in RMP covered processes in 2011 down to #3 in 2017 (see tables below). …...

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An explanation of Certified Welding from the National Certified Pipe Welding Bureau

This publication is without a doubt the best explanation of “certified welding” associated with the American Society of Mechanical Engineer’s (ASME) B31 series of RAGAGEPS.  The contractor is REQUIRED to certify that the welding procedure and the welder are qualified in accordance with the requirements of Section IX of the American Society of Mechanical Engineers (ASME)…...

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“Welder Certification”, What it is – What it isn’t (AWS)

A welder who is considered to be or previously had been “certified” would be supported by some WRITTEN DOCUMENTATION. This documentation would support having met some “prescribed standard.” This standard could be an industry recognized code or standard, a company document or a combination of those and the content of the record should meet the requirements…...

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