Chemical Process Safety (PSM/RMP)

Another WRONG CHEMICAL to the WRONG TANK incident (NH3 to LPG)

Flaring took place over several days at a bulk propane plant after an unidentified third-party carrier, who is used to haul propane to the site, inadvertently offloaded anhydrous ammonia into propane storage tanks at the site.  “It was a driver error on their end, and ultimately there was anhydrous that was in the storage tank…...

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Your OSHA history may just stifle your growth…

This week we learned of a lawsuit in KS regarding the location of a proposed (actually permitted) cold storage facility. Landowners near the facility have filed suit asking a judge to reverse the county commission’s approval of the 411,000 square feet cold-storage facility near their homes. Neighbors say the plan doesn’t provide the right setbacks or…...

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NC EPA RMP Inspections and Citations (2016)

Just an FYI for those of you who have RMP covered processes in the state of NC.  Not much different than what we see with federal inspection data, but there are some interesting differences none the less…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Example of how an Initial Start-Up procedure is different (1910.119(f)(1)(i)(A)

One of the most misunderstood operating procedures in OSHA’s PSM and EPA’s RMP standards is the “Initial Start-Up procedure”. OSHA, nor EPA has offered a lot of written guidance, on this requirement and this has led to a lot of confusion as to why it is called out and how this SOP differs from a…...

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EPA’s RMP Program Level 3 Process Checklist For Ammonia Refrigeration Systems

Many thanks to my friends at EPA (and OSHA) for sharing this EPA RMP Checklist specific to Ammonia Refrigeration Processes.  Here are the “highlights” specific to NH3 processes.  It should be noted that this RMP Checklist specific to Ammonia Refrigeration Processes was developed in conjunction with the International Institute of Ammonia Refrigeration (IIAR) and all EPA Regions. NOTE:…...

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A look into the inner workings of a fatal NH3 release

Information is starting to trickle out from the fatal NH3 release last year. This response was performed by one of, if not the best, Fire Department in the country so we can stand to learn a thing or two from their efforts.  For those who claim LEVEL A suits are an “overkill” for anhydrous ammonia…...

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GUIDANCE FOR CALIFORNIA ACCIDENTAL RELEASE PREVENTION (CalARP) PROGRAM SEISMIC ASSESSMENTS

I found this document extremely helpful and interesting, especially the following sections: Walkdown Considerations Evaluation of Ground Supported Building and Nonbuilding Structures Evaluation of Equipment and Nonstructural Components Evaluation of Ground Supported Storage Tanks Evaluation of Piping Systems CLICK HERE to download… Membership Required You must be a member to access this content.View Membership LevelsAlready...

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Your Risk Management Plan details are available for the world to see – a little bit of attention could save a lot of embarrassment

I have an ongoing project with an entity that takes me on a trip through hundreds of Risk Management Plans that have been submitted to the EPA.  Now most EHS professionals know that the majority of the data and text submitted in these plans is available on the world-wide web for anyone and everyone to…...

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“What’s that Handle For?” A Primer on Lifting Devices (National Board)

This latest edition of The BULLETIN (a National Board Publication) contains another excellent article on handling and managing relief devices.  What caught my eye was the pic they used in the article… As a safety professional, we need to be well versed in our safety devices and this brief article is a great resource from a highly…...

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Ammonia Leak Hospitalization (WA-OSHA Presentation)

In April, 2011, an ammonia leak at a large warehouse where anhydrous ammonia is used in the refrigeration system in a cold storage building. In this incident, one worker was burned on the arm from the escaping gaseous ammonia.  An estimated 3600 pounds of ammonia evaporated into the air during this incident. As part of the…...

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“Layers of Protection” simplified

One of the most often asked questions in my Process Safety training courses is… “What do you mean when you say Layers of Protection?”  So I have made this very simplified powerpoint presentation to provide a visual of how “Layers of Protection” are effective and how they BECOME INEFFECTIVE.  This safety principle is most often mentioned in process…...

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