Chemical Process Safety (PSM/RMP)

RMP reporting requirements, when to update, and how to submit using the new web-based system

Executive Summary (40 CFR 68.155) Mustbriefly describe the following elements Accidental release prevention and emergency response policies at your facility Your facility and the regulated substances handled General accidental release prevention program and chemical-specific prevention steps Five-year accident history Emergency response program Planned changes to improve safety (common deficiency) Be specific! (a general statement on…...

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RMP’s “Stationary Source” and “Incident to Transportation” exemption challenged

A facility buys anhydrous ammonia in railcar quantities, which the Railroad delivers the ammonia to its site, after which it is off-loaded either into “bulk trucks” for delivery, or to stationary ammonia storage tanks. The anhydrous ammonia eventually is sold as both a refrigerant and fertilizer. The company filed a “Tier II Report” identifying its…...

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EPA to audit the CSB????

The title is NOT a type-o!  Yes, the EPA Office of Inspector General will audit the U.S. Chemical Safety and Hazard Investigation Board’s (CSB’s) investigation process.  The EPA OIG’s objective is to determine if CSB has an effective system for managing its investigative process. The OIG plans to conduct its work at CSB headquarters and Denver…...

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PSM Information Collection Requirements

An interesting look at OSHA’s perspective on the written documents needed for comply with PSM!  The information is used by employers to ensure that processes using highly hazardous chemicals with the potential of a catastrophic release are operated as safely as possible. The employer must thoroughly consider all facets of a process, as well as the…...

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The infamous “Process Safety Contractor Safety Study” by the John Gray Institute

The study was commissioned by the Occupational Safety and Health Administration (OSHA) following an October 1989 explosion at a Phillips 66 plastics plant in Pasadena, Texas, that killed 23 workers and injured another 232. The accident involved an outside contracting firm that had experienced a fatality at the same site earlier in the year. These…...

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Phillips 66 Explosion & Fire – Pasadena, TX 1989

This is another great process safety report that is FULL of learning opportunities; a MUST READ for process safety professionals and those involved in their facility’s process safety efforts.  The last article discussed the famous 1974 Flixborough Explosion in the UK.  This catastrophe was a bit closer to home in Pasadena, TX and is considered to…...

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EPA Region X’s RMP “Managment Plan” Example

It may be a sutle suggestion to most, but it is a SCREAMING recommendation to those who struggle daily to get their process safety efforts embedded within their management group.  Too often process safety is delegated to a “one-person” team.  If there is a full-time environmental or safety professional on site, then RMP/PSM is almost…...

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A OSHRC review of PSM Citations following a 32,000 pound release (NH3 Refrigeration)

On August 23, 2010, at a refrigeration plant in Alabama, approximately 32,000 pounds of anhydrous ammonia was unexpectedly released into the atmosphere from a cracked pipe on the suction header on the plant’s roof and a broken evaporator coil in Freezer #5.  The plant was evacuated and an inspection was initiated by OSHA.  On February…...

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Preliminary fire testing of composite offshore pedestrian gratings

Fibre Reinforced Plastic (FRP) gratings can offer a number of attractive advantages over traditional steel gratings such as enhanced environmental resistance, reduced through life costs and the promise of significant mass savings. However, this preliminary study has demonstrated that the current fire certification of FRP gratings by a standardised (ASTM E119 cellulosic fire) time-temperature curve…...

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Perfect example of using the “Elimination/Substitution” in the hierarchy of controls as well as IST

Most safety professionals are aware of the “Hierarchy of Controls: 1) Elimination/Substitution, 2) Engineering Controls, 3) Administrative Controls, and 4) PPE.  Most safety professionals also know this basic principle of industrial safety is often times very difficult to get management buy-in; especially when a safety professional is bold enough to mention eliminating a hazardous chemical for a lesser hazardous…...

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Keep’n it real during the Process Hazards Analysis

Before I begin, nothing I am going to say in this article is required by OSHA or EPA; however, keep in mind that OSHA and EPA process safety requirements are the BOTTOM OF THE BARREL when it comes to true process safety.  So with that said, let’s discuss PHA scenario likelihoods.  Regardless of methodology used,…...

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Some hazards deserve all four levels of controls!

As most, sadly not all, safety professionals will attest to, there is a hierachy of four (4) controls we use to manage risks: 1) Substitution/Elimination, 2) Engineering Controls, 3) Administrative Controls, and 4) Personal Protective Equipment.  In process safety environments, the hazards are often times so great that ALL FOUR layers may be needed.  What…...

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