Both OSHA’s and EPA’s process safety standards have a requirement called “Design codes and standards employed”, but why do the standards require this and what should it look like in our Process Safety Information management system? In a review of our past audits, we almost always find gaps in the facility’s list of Design codes and…...
An analyzer engineer was fatality injured when the engineer removed the cover on an explosion-proof enclosure as part of a routine task. The threaded cover weighing ~12 lbs. and measuring 14 inches in diameter was forcefully propelled from the enclosure as the engineer unscrewed it inflicting a fatal head injury. The force was caused by…...
The Environmental Protection Agency (EPA) is delaying the effective date of the Risk Management Program Amendments for an additional 20 months, to allow EPA to conduct a reconsideration proceeding and to consider other issues that may benefit from additional comment. The new effective date of the rule is FEBRUARY 19, 2019. The Risk Management Program…...
The Department of Labor and Industries cited a refinery for forty-five alleged violations of various Washington Administrative Code sections assessing a penalty of $2,393,000 as a result of an explosion and fire that occurred at the refinery on the early morning of April 2, 2010 that resulted in seven fatalities. The refiner contends that it…...
This week the USDOL-OSHA, Directorate of Enforcement Programs, Office of Chemical Process Safety and Enforcement Initiatives team (Jeff Wanko, Jim Lay and Mike Marshall) presented an update on OSHA’s PSM Activities. This is the first such kind of update in over a year so it has some interesting DATA and updates to OSHA CHEM NEP approach. I have…...
Is there such a thing as a “dual phase” pressure safety valve (PSV)? Not that I have ever encountered; yet that does not stop some from trying to “educate me” on their dual-phase PSVs. So why does this topic matter? Our PSV’s are our LAST LINE of defense in an overpressure event, and if they…...
Recently I had the pleasure of working with a team of engineers and EHS professionals on a PHA project for an Anhydrous Ammonia process. For those who may not know, hydrostatic relief valves are required on Anhydrous Ammonia processes, that are NOT associated with mechanical refrigeration, and unfortunately, there is little guidance on their design…...
There has been some mild interest in this course, with some inquiries about doing “special session” at a facility. Typically these courses are taught for a facility/business and the topics can be revised based on the facility’s need(s). This is NOT an OSHA 10-hour or 30-hour course and I do NOT issue certificates for these…...
In the world of Process Safety Management and processes containing flammable liquids and gases, the management of hazardous locations (HAZLOC) can be very difficult to manage; especially when a facility decides that some of their “Nonincendive” devices are acceptable. The use of “Nonincendive Equipment” is one (1) of the twelve (12) acceptable “protection techniques” offered by NFPA…...
I have always wanted to get a working example of what goes on behind piping insulation once the vapor barrier has been compromised. This video is one from a recent inspection and just happens to be in an NH3 refrigeration process, but this issue is found in any process where the temp of the…...
The Department of Industrial Relations’ (DIR) Occupational Safety and Health Standards Board today approved a landmark regulation to strengthen workplace safety and health at oil refineries across the state. The new regulation provides a framework for anticipating, preventing and responding to hazards at refineries. The approved regulation introduces a new refinery safety order enforced by…...
This is another Wrong Chemical – Wrong Tank incident in which Anhydrous Ammonia (NH3) was off-loaded to Propane Storage Tanks. Two 30,000-gallon propane tanks, each at 70% capacity, were additionally filled to 85% with NH3. Similar plumbing on BOTH transport and storage tanks made the transfer possible, as both propane tanks shared common piping,…...
