Chemical Process Safety (PSM/RMP)

Another example of “Temporary Operations” in Process Safety

As I have mentioned before, this “temporary operations” mode confuses a lot of facilities. Almost all facilities will state, without hesitation, that they have no “temporary operations.”  And almost always, as we proceed with our assessment/analysis, we find numerous “temporary operations.”  As I write this posting, it is -10°F here in Cincinnati, OH, a temperature…...

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Final Refinery Safety Report Calls for Greater Collaboration and Oversight to Protect the Public and Employees (CAL-OSHA)

After more than 18 months of working with communities, workers and industry leaders, the state’s Interagency Working Group on Refinery Safety (Working Group) today released its final report outlining recommendations to improve public and worker safety at and near the state’s oil refineries. A task force has already begun overseeing implementation of many recommendations and…...

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Another PSM Learning opportunity (Line Break, Safe Work Permit, LOTO, PPE, Pipe Labeling)

I want to encourage you to ask around and maybe even go as far as auditing around this learning opportunity to assess if this is going on at your facility.  If your process involves doing preventive maintenance on flame arrestors and/or conservation vents, what controls are in place for this “routine work”?  What kind of…...

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Updating your RMP OCA Populations

Back in September 2013 (Members CLICK HERE) I updated you on the fact that LANDVIEW was going away and how this would impact us this year when it comes time to make our 5-year update.  Now for those of you who are using ALOHA/MARPLOT to plot your Off-Site Consequence Analysis you can get your 2010 census…...

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RISK MANAGEMENT PLAN CO-LOCATION GUIDANCE OF NON-INTERCONNECTED REGULATED SUBSTANCE VESSELS (OH EPA)

 Although this “guidance” is provided by Ohio EPA and is meant for ONLY facilities located in the state of Ohio, this guidance is an EXCELLENT breakdown of how a facility should view “co-located” containers of their Extremely Hazardous Substances to determine if their “co-located containers/vessels” are actually a “process” that would fall under the CAA’s…...

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Food Processing Company Settles Violations of Chemical Release Reporting Requirements (NH3 Refrigeration)

EPA announced that a food processing facility has agreed to pay a $19,049 penalty for failing to properly report an ammonia release at its facility.  According to EPA, the facility released at least 450 pounds of anhydrous ammonia to the air on September 12, 2012. Employees were evacuated and the local Fire Department responded to a 911…...

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Process Safety Operating Procedures and a Certified PPE Hazard Assessment

This week, OSHA once again showed their intent to issue PPE citations during PSM NEP audits.  They are very content to issue a citation against 1910.132(a) or (d) when the process contains a flammable liquid and somehow the employer’s PPE Hazard Assessment determined that Flame Retardant Clothing (FRC) is not necessary.  But there is another…...

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Is your facility REALLY prepared for an emergency? (ERT and PSM SOPs)

Over the past several months we have been working with a confidential client who has afforded me with permission to post this “learning opportunity” for others.  This incident, although minor this time, was recognized as having the potential to end the business so this organization is pulling out all the stops to identify failures.  Once…...

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Vibration-induced fatigue on process pipework

What happened? During a recent inspection at a facility, an NOPSEMA inspector observed vibration-induced fatigue cracking and evidence of rectification work carried out on several small-bore connections on seawater cooling pipes. On further investigation, it was discovered that there had also been a recent fatigue failure on the hydrocarbon test separator header. Fortunately, the operator…...

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Are we “dumbing” down RAGAGEPs to make OSHA’s job harder?

Early last year I wrote about some trade organizations that were “revising” their codes/practices, which in turn were making them “more flexible”.  I stated it then and I will state it again, this time along with the US Chemical Safety Board… this is a REALLY BAD idea.  Both OSHA and EPA wrote “performance oriented” standards…...

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API provides OPEN/FREE access to many of their codes/practices

Ever wanted to know what an American Petroleum Institute (API) code or practice said?  Well now you may be in luck; as API is providing online public access to many of their key industry standards, including a broad range of safety standards, most of which were previously only available by purchase. These standards will be…...

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How rigorous is your contractor safety evaluation(s)?

Recently the SAFTENG team was hired to provide some safety services during a turn-around/shutdown at a PSM/RMP facility . While out and about we came across a very interesting find… a speciality contractor with facial hair. Now this was not just any speciality contractor and the reason we were so surprised was the facility had,…...

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