Chemical Process Safety (PSM/RMP)

Discharging Pressure Vessel RVs back into process

PLEASE NOTE: this posting is about pressure vessel RVs discharing back into the process and not Hydrostatic RVs or pump RVs. Scenario: Process is shutdown using the emergency stop (e-stop) systems because the building is on fire. On the roof of the building/plant sit a number of vessels that have a “flooded system” which contains…...

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INTERIM CHEMICAL ACCIDENT PREVENTION ADVISORY – Design of LPG Installations at Natural Gas Processing Plants

US EPA is concerned that some natural gas processing plants that store and process liquefied petroleum gas (LPG) may not be designed in accordance with applicable industry standards and codes. When undertaking compliance monitoring activities at such natural gas processing plants, EPA considers whether facilities are designed in accordance with recognized and generally accepted good…...

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2014 Public Listening Session Schedule and Registration Information EO 13650 Improving Chemical Facility Safety and Security

Please join us for the Improving Chemical Facility Safety and Security (Executive Order 13650 (EO)) public listening session opportunities in January 2014. The EO Working Group anticipates having evening hours for several of the locations. Updates to the January public listening session schedule will be available on the Website: https://www.osha.gov/chemicalexecutiveorder/index.html and shared via e-mail. If…...

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Does PSM/RMP standards need a Ultimate Work Authority and Stop Work Authority concepts?

Recently OSHA has “requested information” regarding certain aspects of their Process Safety Management standard. In this effort, OSHA has suggested that the standard is revised to clarify certain aspects and to include some items they feel are needed. In the public posting, OSHA stated they are considering adopting management-system elements from safety standards that other…...

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UPDATE – State of MA Hazardous Material Process or Processing: 527 CMR 33

January 1, 2014, Deadline for Category 2 & 3 Processes Permit Applications Category 4 hazardous material tank The final deadline for the phased-in implementation by category of process and vessel size was January 1, 2014. All first-time applications for permits for Category 2 and 3 processes covered by 527 CMR 33.00: Hazardous Material Process or…...

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HAZCOM labeling changes and your PSM/RMP programs

With the required HAZCOM GHS labeling and SDS training now behind us, I wonder how many PSM/RMP covered facilities actually considered these “changes” to our site chemical labeling scheme something that would warrant a MOC?  There are many professionals that would make the argument that an HAZCOM program has nothing to do with PSM/RMP compliance;…...

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De-Rating or Re-Rating a Pressure Vessel

Before de-rating or re-rating any ASME Pressure Vessel, a request from the owner/user shall be made to the Principal Pressure Vessel Engineer per R-503, National Board Inspection Code 1992 Edition, and RC-3022 of the NBIC 1998 Edition. The following information shall be included in a request from the Owner/User:… Membership Required You must be a...

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CSB Draft Report Proposes Overhaul of Refinery Industry Regulatory System in CA and Urges Adoption of the “Safety Case Regime” to Prevent Major Chemical Accidents

In a draft report released to the public today, the U.S. Chemical Safety Board (CSB) proposes recommendations for substantial changes to the way refineries are regulated in California. Entitled “Regulatory Report: Chevron Richmond Refinery Pipe Rupture and Fire,” the CSB draft calls on California to replace the current patchwork of largely reactive and activity-based regulations…...

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Acting Responsibly? Federal Contractors Frequently Put Workers’ Lives and Livelihoods at Risk

For those of us living the process safety world, we will find this report laughable! By that I mean, we have to evaluate our contractor’s safety performance before hiring them to work in, on or adjacent to our covered processes, but apparently the government does not see the value in evaluating the contractors it hires!…...

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ASME’s Single Certification Mark (new nameplate)

ASME has introduced a new Certification Mark with the 2011 Addenda to the Code. All new applicants receive the Certification Mark this year. Until December 31, 2012, the Code Symbol Stamps may still be used, but will be replaced by the new Certification Mark together with the designator letter “U”, “S”, “PP”, etc. As of…...

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Training requirements for mechanics repairing and/or testing pressure relief devices

This letter constitutes OSHA’s interpretation only of the requirements referenced below and may not be applicable to any question not included in your original correspondence. You inquire about OSHA’s standard for Process Safety Management of Highly Hazardous Chemicals (PSM), 29 CFR 1910.119. Specifically, you ask about for mechanics repairing and/or testing pressure relief devices. We…...

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