Chemical Process Safety (PSM/RMP)

Playing “Who’s on first, What’s on second, I Don’t Know is on third” – with EPA’s R-134a refrigerant replacement (HFO-1234yf)

I may have been quick to “pat myself on my back” last week with my post titled “It took two (2) years, but HFO-1234yf is now a NFPA Flammable “4”, as this morning I learned from another client dealing with this refrigerant that their manufacturer also updated their SDS and guess what… that manufacturer went…...

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Is your car a traveling PSM covered process?

I have joked about this topic in other posts, as we have been battling the idea that our new refrigerant for vehicle air conditioners is a Category 1 Flammable Gas.  This conversion from R-134a has been a bumpy one, but in jest, I share with you EPA’s “use conditions,” and for an agency that certainly…...

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It took two (2) years, but HFO-1234yf is now an NFPA Flammable “4”

Back in early 2015, I began working with some clients who were questioning their having to enter into the Process Safety arena because of a new refrigerant that was going into automobiles.  Early in our discussions I was appalled that this flammable refrigerant had been “marketed and sold” with the description of being a “mildly flammable”…...

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Flaring off NH3 and a few things to consider

This week social media once again provided us an eye-opening video… flaring off an MC331 Tanker of anhydrous ammonia (NH3).  In my days, I have flared off both tanker trucks and railcars, and even worked with flaring systems on refrigerated atmospheric bulk storage tanks of NH3 at large NH3 terminals and NH3 manufacturing plants.  The…...

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Fatal Hot Work – Tank Explosion (September 2017)

                                            This week we saw another fatal hot work explosion associated with welding on a container/vessel.  This time we lost a 29-year-old father, who was supposedly standing on or next to the tank when it…...

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DHS’s Chemical Facility Anti-Terrorism Standards (CFATS) October 2017 Update

Identifying Facilities as High-Risk and Regulating Site Security, the CFATS regulatory program uses a risk-assessment methodology to identify high-risk chemical facilities. DHS determines risk profiles by requiring facilities that possess specific quantities of chemicals of interest (COI) to complete a questionnaire, known as a Top-Screen, on their chemical holdings. Facilities determined to be high-risk must…...

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“UPWARD” actually means UP, which is the opposite of down in RV Discharge Design

Relief System Design is not actually rocket science, so when our Recognized and Generally Accepted Good Engineering Practice (RAGAGEP) tells us that our relief valve discharge is to be in the “Upward” direction, this is not meant to be a “trick question”. But it does seem to stump a lot of engineers, case in point……...

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Can we have more than the PSM or RMP thresholds on site and not be covered under PSM or RMP?

The short answer is ABSOLUTELY WE CAN, but we need to be very careful about how we manage our hazardous materials. The purpose of this article is to clear the air about EPA’s use of our own Tier II reports against our facility… they can be an “indicator” of PSM/RMP covered processes but they are NOT…...

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NFPA 51B, NFPA 241, and your Fire Watch requirements

One of the debates we routinely have with fellow process safety professionals is the adoption of NFPA 51B vs. meeting 1910.252(a) requirements for their Hot Work safe work practice. I am a huge fan of NFPA 51B, as it is much more up-to-date than OSHA’s 1910.252; which by the way was based off of the…...

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$2.7 Million in Damages from Faulty Sight Glass Valves (BSEE Bulletin)

Check-valves are utilized in all sorts of applications, including safety applications – most notably in process safety and hazardous materials safety.  In some state fire codes, these valves may even be required in certain lines, and in some process safety RAGEGEPs, they are required.  Although this incident occurred in an off-shore rig, the sight-glass involved…...

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OSHA’s new publication “Process Safety Management for Petroleum Refineries”

OSHA has just released a new PSM Booklet titled “Process Safety Management for Petroleum Refineries,” which contains “Lessons Learned” from their Petroleum Refinery Process Safety Management National Emphasis Program (NEP).  This publication is a MUST READ for any practicing process safety professional, regardless if your process(s) is a refinery or not!  The publication focuses on…...

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