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 […]
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
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
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
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
