Chemical Process Safety (PSM/RMP)

Part II – BFD Fatality Report on NH3 Refrigeration Fatality (March 2016)

This is my second and probably the last post regarding this incident.  This post will cover the Boston Fire Department’s (BFD) activities that took place at the facility AFTER the fatality.  As you can see, these guys are true pro’s and they know hazardous materials as well as did a nice job using IIAR-2, American National…...

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A sign of the times for the USA and our HAZMAT Facility Siting?

This anhydrous ammonia (NH3) refrigerated storage tank (photo source: Jerusalem Post) was feared to be a target of terrorist and as one report claimed, imminent failure.  The battle heated up in 2013 when “Hezbollah” (a recognized terrorist group) threatened to blow up the tank (or the ship delivering the NH3) with missiles and the courts…...

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Niffty infrared video of an NH3 release @ cold storage warehouse (Video)

Fire officials have an idea how much ammonia leaked from a cold-storage business but can’t say exactly how long it spewed. Roughly 60 pounds of the material leaked fire Capt. James Brown said. Investigators believe the leak was caused by a valve that wasn’t completely closed while the business was closed. No one was required…...

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EPA’s new “Final Rule” Risk Management Program (RMP) (August 2017)

It certainly looks like EPA has been busy with their review of the proposed amendments to the RMP Rule.  To that fact, they have released this Q&A explaining what they are keeping, what they eliminated, and what they revised in their NEW FINAL RULE.  This new FINAL RULE is set to take effect on 2/19/2019…...

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Two Ammonia Refrigeration Technicians Sustain Corneal Burns

At approximately 9:50 a.m. on October 24, 2012, Employees #1 and #2 were working as mechanical engineering technicians at a food cold storage facility. The two workers were troubleshooting a Hansen Technology Model AP08 Auto-Purger. The Auto-Purger removed non-condensable material from the refrigeration system. It was mounted on a wall inside the facility’s anhydrous ammonia…...

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Draining oil from NH3 refrigeration process flash fire fatality

Its 2017 and we still debate the flammability of anhydrous ammonia (NH3).  It is a fact that NH3 is not classified as a “flammable gas” due to its high Lower Explosive Limit (16%) and it’s flammable range being less than 12 percentage points.  But there is one other fact that we seem to lose sight…...

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BFD Fatality Report on NH3 Refrigeration Fatality (March 2016)

I have finally received the investigation information regarding the anhydrous ammonia fatality at a refrigerated seafood warehouse in Boston in March 2016.  Sadly these reports do not indicate the cause of the accident and it does not appear that the AHJ used the state’s 527 CMR 33.00: Hazardous Material Process or Processing to enforce the…...

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A PERFECT example of Inventory Management and Inherently Safe Design (CL2 & $220K)

Here we have a darn near perfect example as to why OSHA/EPA are now asking businesses with PSM/RMP covered process to “justify” their “maximum intended inventory(s)” of their Highly Hazardous Chemicals (HHC)/Extremely Hazardous Substances (EHS).  The business had, at the time of the EPA inspection four (4) 1-ton cylinders of Chlorine in the same room…...

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Georgia’s Insurance & Safety Fire Commission issues Pressure Vessel Code violations following Nitrogen Fatality ($302K)

NOTE:  This case, as unfortunate as it is, stands in a very small group of State Fire Code violations, and in my memory stands atop of the pile @ $302,500.  It is rare for a state to issue code violations and even more rare for the dollar amount to be so high.  The one thing…...

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Steps required to correct or avoid deviation (1910.119(f)(1)(ii)(B)

Both OSHA’s and EPA’s process safety standards require operating procedures to contain the “steps required to correct or avoid deviation(s)”, but what exactly does this mean?  I really wish OSHA/EPA would have phrased it as “avoid or correct” as putting the words in this order is actual reality. Let’s look at a simple process set-up…...

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Ammonia Refrigeration FATALITY – Hot Gas Defrost Valving Error

UPDATED 8/15/2017 with OSHA Case info:  This has now been classified as a “Hot Gas Defrost Valving Error”. On September 11, 2012, Employee #1, a temporary employee was working as a racker-blender at the [wine company], was exposed to anhydrous ammonia, and died of asphyxia. Employee #1 was found in the west hallway 54 ft…...

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DHS CFATS follows suit on “motive power” and application of the standard

FAQ Number: 1784 Date Published: August 04, 2017  Question: Does a facility have to count theft/diversion chemicals of interest in transportation packaging towards the screening threshold quantity if the packaging is on or attached to motive power to include overnight? Answer: Yes. 6 CFR Part 27.203(c) states that facilities must calculate theft/diversion chemicals of interest in transportation…...

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