Chemical Process Safety (PSM/RMP)

Already, in less than 24 hours from when I posted the OSHRC decision on the BP Refinery, I have received over a dozen e-mails asking me “do I have to have U-1 forms for my pressure vessels?”.  There are not many PSM/RMP facilities that have not been dinged with one of these findings over the…...

On March 8, 2010, the Secretary issued three citations to a refinery, alleging twenty serious, forty-two willful, and three other-than-serious violations of the Occupational Safety and Health Act of 1970 (Act), 29 U.S.C. §§ 651, et seq. The Secretary issued the citations following an inspection conducted by the Occupational Safety and Health Administration (OSHA) at…...

For new processes, you must document both material and energy inputs and outputs of a process. For example, you would document the quantity of a regulated substance added to the process, the quantity consumed during the process, and the quantity that remains in the output. This requirement will not generally apply to storage processes.  CLICK…...

In the past couple of months, I had several conversations with process safety professionals asking about “running equipment to failure” within a chemical process handling a highly hazardous chemical (HHC) or extremely hazardous substance (EHS). These discussions were often lively and I was actually called “a consultant” “that needed to walk a mile in my…...

The National Board of Boiler and Pressure Vessel Inspectors has released its First Quarter Report of Violation Findings for 2013.  The modified violation tracking system launched in July 2012 and captures a clearer picture of problem areas and trends related to boiler and pressure vessel operation, installation, maintenance, and repair. The data also identifies problems…...

The National Board has announced 1,530,716 registrations of boilers, pressure vessels, attachments, and nuclear equipment for the fiscal year 2013 (July 1, 2012–June 30, 2013).  The National Board maintains manufacturers’ data reports on all boilers and pressure vessels registered with the National Board. Each data report includes the name of the manufacturer, the item’s National…...

More than 44,000 preliminary assessments were reviewed by DHS from facilities with chemicals of interest 4,298 facilities are currently covered by CFATS More than 3,000 facilities voluntarily removed, reduced, or modified their holdings of chemicals of interest 1276 visits to assist facilities with compliance 589 Security Plans authorized 182 Security Plans approved following an onsite inspection…...

Section 27.110(b) of 6 CFR exempts from CFATS “Treatment Works,” as defined in section 212 of the Federal Water Pollution Control Act, Pub. L. 92-500, as amended. If an industrial facility treats its wastewater and that water is directly discharged into a body of water without further treatment, then the facility must be registered with…...

UPDATED 8/17/14 Routinely we hear the argument that Anhydrous Ammonia should not be on OSHA’s or EPA’s chemical lists for PSM/RMP inclusion.  Like most industries that use a single highly hazardous chemical as a “utility” in their process(es) v.s. manufacturing the HHC or using the HHC in the manufacturing process, these industries feel “their chemical”…...

The White House, Office of the Press Secretary For Immediate Release August 01, 2013 EXECUTIVE ORDER – IMPROVING CHEMICAL FACILITY SAFETY AND SECURITY By the authority vested in me as President by the Constitution and the laws of the United States of America, it is hereby ordered as follows:    Section 1. Purpose. Chemicals, and the facilities…...

A common situation we find is that facilities struggle to understand how their “initial start-up” procedure for a new piece of process equipment can/will differ from their other start-up procedures for the equipment (e.g. normal, after a turnaround, after an emergency shutdown, etc.). Recently I have learned of a process used on galvanized condenser coils/tubes that…...

There is one small little sentence in 1910.119 (as well as Part 68) that is causing all kinds of heartburn. I like to call this requirement the “General Duty Clause” of process safety. To fully understand what this requirement entails we first have to understand what is meant by a standard being a “performance oriented”…...