Chemical Process Safety (PSM/RMP)

If I do RT examinations of 100% of my pipe welds, do I get any exemptions for pressure/leak testing?

The short answer is no. Radiographic Testing (RT) and pressure testing (Hydrostatic or Pneumatic) serve two (2) fundamentally different purposes in piping integrity. While it might seem like “over-testing,” they are not interchangeable in ASME B31.3 (Process Piping) or ASME B31.1 (Power Piping). Here is the breakdown of why 100% RT does not exempt you…...

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How much toluene does it take to make a room 40’X40’X8′ to achieve its LEL%?

My SDS list toluene’s lower explosive limit (LEL) as 1.2% by volume, often given as:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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AI is not the answer to all of our safety questions!

I was playing around with Google Gemini and wondered about its limitations and accuracy. One of the problems in my HAZMAT courses is showing just how small an amount of Cl2 it takes to achieve an IDLH concentration in a given space. So I asked it.. How many pounds of Chlorine Gas will it take…...

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Process Safety introduced the MOC to many, but it did NOT create the MOC

One of my most debated topics at SAFTENG is my writings/ramblings about the critical role that a Management of Change (MOC) plays in ALL of safety, not just PSM. I’ve been involved in numerous non-PSM/RMP accidents that can be traced to poor or non-existent change management. One fatal event last year involved simply moving a…...

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JLG strikes NH3 pipe leading to a fatality

Workers were weatherproofing the outer layer of a large ammonia storage tank when contractor-operated equipment struck a bleed pipe, causing an unplanned release of ammonia. Two (2) workers were exposed to ammonia, one worker suffering fatal injury and the other worker suffering minor injuries. NOTE: Another case of an EEBA not working because it was…...

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Line Break gone bad (Hot Oil)

A refinery has been fined more than $182,000 by WorkSafeBC after an incident that saw an employee’s clothing sprayed with hot oil. On Wednesday, April 8, WorkSafeBC put out a media release regarding the incident and a corresponding penalty of $182,282.38 levied against the refinery on Tuesday, Feb. 24, 2026. A summary posted on the agency’s…...

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Human Factors 101 – Gauges

Snapped this pic on a PSM-covered process. Can you see what it is? Yep, it’s a gauge; a Safety Critical gauge at that. But can you read the gauge? I took the pic at no zoom, so you can get a feel for the level of challenge in reading this “safety critical” gauge, which is…...

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Do you see the need for a Car-Seal?

Snapped this pic this week and thought it would be a great pic to start a discussion about Car-Sealing valves in their OPEN position. And yes, Car Seals are for more than just Pressure Relief Systems. In the pic below, there are two (2) valves that are candidates for Car Seals; one (1) of the…...

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Does your Process Hazards Analysis (PHA) require teams to consider the PREVENTION, PROTECTION, and MITIGATION layers of protection?

Whenever I facilitate a PHA for a client who is serious about the exercise, I always create a visual on a white board so the team can methodically discuss ALL the safeguards/barriers/controls that are present to PREVENT-PROTECT-MITIGATE the event being studied. It looks like this:… Membership Required You must be a member to access this...

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When tours or demos go bad (Niederstedem Tank Explosion – EPSC Learning Sheet April 2026)

CO2 as solid particles can cause electrostatic discharge! In September 1953, an aircraft fuel storage farm was taken into use in Niederstedem, Germany. The automatic fire extinguishing system, which used CO2, was demonstrated to visitors on the roof of the storage tank. The tank containing an explosive mixture suddenly ignited and exploded. 29 people lost…...

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Would you accept this repair for one of your Polyethylene Storage tank?

I guess we are never too old to learn new tricks! This week, I came across a practice that I was 100% certain I was being “punked.” The practice is called “welding,” but it’s done on a Polyethylene Plastic tank! Technically, it meets the definition of “welding”… Welding is a fabrication process that joins materials—typically…...

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Storing 19% Aqua Ammonia Outside can be tricky

Over the past decade, we have received dozens of requests from both current and new clients seeking to move to 19% Aqua Ammonia, so the process is NO LONGER RMP-covered. (NOTE: OSHA only covers 44% or higher Aqua Ammonia; EPA begins its coverage at 20%). This is taking the “inherently safe” approach to process safety…....

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