Chemical Process Safety (PSM/RMP)

Pipe Systems – their QA labels and their supports (2015 IMC)

The 2015 International Mechanical Code (IMC), Chapter 3 – General Regulations lays out the baseline requirements for all piping systems, including hydronic, refrigerant, condensate, fuel oil.  The Chapter, and more specifically Sections 301 and 305, covers how the pipe manufacturer must identify the pipe (e.g. this is the label we use in our QA efforts to…...

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EPA amended RMP “Availability of information to the public”

So in the last month, I have heard four politicians lay claim that EPA’s amended Risk Management Plan rule will actually make “us all” much less safe because of the “public access” part of the amendments. So let’s see what all the fuss is about and what is scheduled to start on March 21st.  I…...

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Worst-case release scenarios for toxics and flammables involving the same process

Question: At my facility, if the worst-case release scenarios for regulated toxic substances and the worst-case scenario for regulated flammable substances involve the same process, must I analyze both?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Yep… it’s just ammonia (OSHA Database Accidents)

Here are some “official” accident facts from OSHA regarding fatal accidents involving Anhydrous Ammonia (all but 1 of the accidents involves Anhydrous NH3).  These incidents can be found in OSHA’s Accident Database, but all the accident info is provided below.  I have scrubbed company names from this posting, as this is meant to be a…...

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Line Break(s) gone bad (Chlorine)

#1 At approximately 7:00 p.m. on November 15, 2006, Employee #1 was a process operator at the Chlorine Liquefaction Unit, Block A-19. He was preparing to bleed off chlorine on a process line, to clear the line for maintenance work. The valve handle indicated that it was in a closed position. Employee #1 opened the…...

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Is your plant speed limit based on engineering or a whim

If you’ve ever driven on an industrial plant site you most likely have noticed the speed limits on these sites is rather low, say 10 mph.  However, some sites we have visited we have seen speed limits up in the 20 mph range.  Now if there is no critical infrastructure in the area, we just…...

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EPA delays amendments to the RMP rule

Nice headline huh?  Don’t order the cake and party horns just yet, as the delay is a whopping seven (7) days and NO that is not a type-o!  In accordance with the Presidential directive as expressed in the memorandum of January 20, 2017, from the Assistant to the President and Chief of Staff, entitled “Regulatory…...

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US CSB Video “Blocked In” (Heat Exchanger failure due to isolation from RV)

This is the second CSB investigation since 2008 involving a catastrophic failure of a heat exchanger (e.g. pressure vessel) that resulted in a fatality and in BOTH accidents, the heat exchanger had been ISOLATED from its relief protection.  CLICK HERE for the 2008 Heat Exchanger Accident Report which involved maintenance work on the vessel which…...

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Another PSM/Safety tip from International Mechanical Code (IMC)

In our line of work we come across a lot of mechanical ventilation systems that are intended to control/reduce quantities of hazardous gases/fumes/vapors in processing/work/storage areas. And in many cases the facility will hand us a document from a designer/contractor that shows the ventilation system has fans that can meet the CFM prescribed in their…...

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OSHA issues REVISED 2017 National Emphasis Program for PSM Covered Chemical Facilities

This week OSHA issued a REVISED PSM NEP.  This instruction describes an updated initiative by OSHA. Under the previous related instructions, OSHA conducted inspections of facilities covered by OSHA’s PSM standard either through an instruction specific to petroleum refineries or an instruction related to all other PSM covered chemical facilities excluding petroleum refineries. This REVISED instruction is applicable…...

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