Chemical Process Safety (PSM/RMP)

Here is a look at the 12 things OSHA wants to revise with regards to the PSM standard and its enforcement: Clarifying the PSM Exemption for Atmospheric Storage Tanks Expanding PSM Coverage and Requirements for Reactivity Hazards Updating the List of Highly Hazardous Chemicals in Appendix A of the PSM Standard Revising the PSM Standard…...

Please click here to download the CSB follow-up letter to DOT regarding emergency shutdown systems for chlorine railcars.  After investigating two incidents involving uncontrolled releases from chlorine railcars, the CSB issued a safety bulletin, Emergency Shutdown Systems for Chlorine Transfer, in June 2007. At that time, the Board also recommended that the U.S. Department of…...

For those who fall under EPA’s RMP rule, you are familiar with the three (3) program levels your process(s) will fall under and each of these program levels has varying degrees of hazard recognition requirements.  Many professionals involved in process safety are familiar with the term Process Hazards Analysis (PHA), but an RMP Program 2…...

This response to your letter regarding training requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a truck driver who is responsible for loading and unloading hazardous materials from a cargo tank motor vehicle with the power unit attached. Specifically, you are unclear on whether the Occupational Safety and Health Administration…...

A first (1st) public review of draft standard BSR/IIAR 2-201x, Safety Standard for Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems is now open. The International Institute of Ammonia Refrigeration (IIAR) invites you to make comments on the draft standard. Substantive changes resulting from this public review will also be provided for comment in a…...

The National Board of Boiler and Pressure Vessel Inspectors has released its Second Quarter Report of Violation Findings for 2013.  The data captures problem areas and trends related to boiler and pressure vessel operation, installation, maintenance, and repair; and also identifies problems before unsafe conditions occur.   This report serves as an important source of…...

The recent CSB report involving a catastrophic failure of a pressure vessel is causing quite a stir among engineering, safety, and process safety circles. I have received several e-mails and a couple of phone calls claiming the CSB incident is “very rare” and that the vast majority of pressure vessels are managed properly. Much like…...

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Revision 16 of this pamphlet includes the addition of a section on fully-lined valves (4.1.9), a more robust section on liquid expansion chambers (5.5), recommendations on plastic pipe selections and discussion on gas permeability under vacuum (9), a caution on pneumatic testing (11.2.2), updated guidance on hydrostatic testing (appendix A, 2.3.1), and addition of a…...

One area that is often overlooked or not applied during process hazards analysis (PHA) is a review of previous incidents.  This is often not done as the process has no reported incidents in the past five years.  We can discuss/challenge that “phenomenon” in a later posting, but I wanted to offer this bit of advice……...