Over the last decade or so it has become popular to utilize a “relief header” in the ammonia refrigeration process. And in more recent years, the practice of installing an ammonia detector in this relief header has become very popular. Here are some random thoughts about these detectors that employers need to think through when…...
Just some random thoughts about “Detectors in my header” Read More »
On 28th August 1992, in a food factory, a liquefied nitrogen storage tank catastrophically failed, causing the destruction of the upper half of the factory as well as damaging other factories and structures partially, including the outer walls, window glass, and shutters of 25 buildings, 39 parked vehicles consisting of busses, trucks and cars, and…...
UK’s HSE provides some EXCELLENT guidance on how ammonia refrigeration process safety can be managed. We have always taught our process safety courses with the underlying philosophy of process safety as PREVENT, PROTECT, MITIGATE, and in this HSE material they follow the same philosophy. This information is particularly helpful as they have matched up the…...
UK’s HSE guidance on failure modes in Refrigeration Processes Read More »
Today I learned of yet another SIGNIFICANT difference in complying with EPA’s RMP vs. OSHA’s PSM. Yes old dogs can learn new tricks and I am betting that I may not be the only old dog “out of compliance” with 68.200! We have been assisting a company with a US EPA RMP inspection and in…...
SOP annual certifications and 40 CFR Part 68.200 Recordkeeping (RMP) Read More »
We all are aware of… 68.25(h) Consideration of passive mitigation. Passive mitigation systems may be considered for the analysis of worst case provided that the mitigation system is capable of withstanding the release event triggering the scenario and would still function as intended. So I wish to challenge the claim that a WCS inside an…...
Is your Engine Room capable of withstanding your WCS? Read More »
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FREE EPA RMP Training for Ammonia in Ag Read More »
Recently I was asked to help an organization with their Line Break/Process Opening Procedure and Permit. Anyone who has been through this process quickly realizes there is ZERO guidance from OSHA or any RAGAGEP as to what needs to be in the program and most notably the scope of the program. This organization has several…...
Just an FYI, as I know many of you are working on your 2014 5-year resubmittal, EPA issued an update to the RMP*eSUBMIT Users’ Manual in March 2014. No real changes in the manual other than some nice additions of “screen shots”. Here is a link to the new 2014 manual: http://www2.epa.gov/sites/production/files/2013-11/documents/rmpesubmit_users_manual.pdf … Membership Required You must...
RMP*eSUBMIT Users’ Manual 2014 Update Read More »
We can get the 3rd degree when we start poking around a facility’s safety instrumented systems(s). It seems that there are those who believe they can build a SIS that no human can screw up and oh how wrong they are! Even OSHA was smart enough to require us to consider the consequences of the…...
High Pressure Shutdown Switch Fails – Catastrophic Equipment Failure Read More »
I have received numerous e-mails and phone calls seeking help with using MARPLOT to obtain RMP OCA Populations so that this year RMP update will use 2010 Census Data. As I wrote last year, LANDVIEW is no longer a viable option and EPA has instructed us to use “other sources” specifically mentioning MARPLOT as an…...
Using MARPLOT to obtain your 2010 Census data for your 2014 RMP UPDATE Read More »
Recent inspection programs for metallic pressure containment vessels and tanks have revealed cracking and damage in a considerable number of the vessels inspected. Safety and hazard evaluations of pressure vessels, as also presented in OSHA Instruction PUB 8-1.5, need to consider the consequences of a leakage or a rupture failure of a vessel. Two consequences…...
PRESSURE VESSEL GUIDELINES (OSHA 2014) Read More »
In the past 20 years or so we have seen Flame Resistant Clothing (FRC) come a long way in its design, ability, and costs that is VERY MUCH in favor of the end user and businesses. However, we still see the use of FRC as a much-overlooked layer of protection in many facilities and in…...
Flame Resistance Clothing (FRC) program needs Read More »
