Chemical Process Safety (PSM/RMP)

ASME B31.3 makes it clear that hydrostatic leak testing is PREFERRED

One of the most often overlooked requirements for piping installations is the proper leak/pressure testing of the piping BEFORE it is placed into service.  The next major issue found, when piping is tested, is the manner in which it was tested.  The 2014 and 2016 editions of ASME B31.3 makes it clear that hydrostatic testing…...

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EPA RMP Amendments proposed delay until February 19, 2019

This week EPA’s Administrator signed a proposed rule to further delay the effective date of the RMP rule amendments for 20 months until February 19, 2019. This action will allow EPA to consider several petitions for reconsideration of the RMP rule amendments and take further regulatory action. EPA will hold a public hearing regarding the…...

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Process Safety Management Course – Advanced (4/3-4/7/2017)

I have been given permission to OPEN up a PSM Training course in April to other clients/members.  This is a 4.5 day training course and involves field-work, so you will need to bring your PPE (Safety Glasses, Safety Boots, Hard-Hat, and FRC if you have it).  The course will be taught with a focus on Category…...

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State of CA ups the Refinery Contractor Safety Training requirements via state Hazardous Materials Management Code

All workers for building trade contractors at REFINERY FACILITIES must complete a MINIMUM of 20 hours of approved advanced safety training by January 1, 2018, AND are required to do so every two (2) years thereafter. This requirement was added to the California Health and Safety Code in Section 25536.7.  To confirm that a worker…...

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OSHA’s intent with the PSM “retail exemption”

As the ballons were filled and the cake was cut, several industries got what they worked so hard to achieve… OSHA can not revise the PSM “retail” definition without going through the Public Rule Making process.  But those who take process safety and risk management seriously may be surprised to know that OSHA had already…...

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OSHA, PSM, “Retail”, and LOI’s

It amazes me how society, specifically lawyers and politicians, can be so collectively ignorant.  With all the change in the political winds some industries are breathing a sigh of relief regarding OSHA’s efforts to redefine “retail” when it comes to the “retail exemption” found in their Process Safety Management (PSM) Standard.  For the record, I did…...

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UPDATE: Final Amendments to the Risk Management Program (RMP) Rule

EPA received a petition dated February 28, 2017, from the RMP Coalition, representing several trade associations. The petition requests a reconsideration and request for stay for the RMP rule amendments, published January 13, 2017.   On March 13, 2017, EPA’s Administrator convened a proceeding for reconsideration of the RMP rule amendments.   On March 16,…...

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738 pound Chlorine (Cl2 ) Release Investigation Report

Incident Overview 738 lbs of Cl2 released from T-103, the Nash compressor seals, and leaking gasket on the suction piping at the Nash compressor.   Event Time line:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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EPA Extends Comment Period on Risk Management Plan Rule

U.S. Environmental Protection Agency (EPA) Administrator Pruitt took action today to reconsider the “Accidental Release Prevention Requirements: ‘Risk Management Programs Under the Clean Air’” (“RMP Rule”) and signed an administrative stay to DELAY the effective date of the rule regarding chemical accident preparedness and prevention, until June 19, 2017.  The 90-day extension will allow time…...

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Right-To-Know Website is BACK thanks to the Houston Chronicle

Just an FYI, the RTK.net database is back up with a NEW look and a couple new features.  Instead of having to sort the data using the table functions, they have sorted some of the data for us.  The site is now run/supported by the Houston Chronicle and can be found at its original address:  www.rtk.net…...

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It’s a bird, It’s a plane, no… it’s a pressure vessel (BLEVE 2017)

A chemical plant where chlorine is manufactured suffered a Vertical Pressure Vessel BLEVE, at least from video footage it appears to be a BLEVE.  It involved a vertical tank, as can been seen in this video, as well as a flammable Liquified Pressurized Gas, as evident when the vessel lands.  Hopefully, we will learn more in the…...

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