Chemical Process Safety (PSM/RMP)

Challenging the NH3 Refrigeration & Electrical Classification (UPDATED 3/3/12)

Most ammonia refrigeration personnel know their refrigerant is flammable, but most would also tell us that they do not have any “Hazardous Locations” (e.g. Class 1, Div 1 or 2 locations) associated with their refrigeration process.  Most of these workers will explain their engine room/compressor room ventilation system is designed, installed, and maintained to ensure…...

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Is the act of loading/unloading a PSM/RMP chemical exempt from OSHA/EPA enforcement?

Is the act of loading/unloading a PSM/RMP chemical exempt from OSHA/EPA enforcement?  Absolutely not!  Somewhere this little fib began and it has spread like wildfire.  If you have a release of your HHC/EHS during unloading or loading, rest assured OSHA and/or EPA can investigate and inspection, and here’s why…… Membership Required You must be a...

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Can a PHA done for OSHA’s PSM be used for EPA’s RMP Compliance?

This is not meant to be a trick question, but many think it is.  A close examination of the specific wording in the PHA element of the RMP rule will quickly identify DIFFERENT wording than what is in OSHA’s PSM std (just another example of how these standards are NOT identical!)…. Membership Required You must...

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How many threads of a bolt must be showing outside a nut to meet RAGAGEP?

NOTE:  Members should also read Process Safety and our pipe flanges (type of bolts, threads showing, etc.) Some may claim this to be a trick question.  I assure you it is not meant to be, but as I will point out in this article, having too much bolt extending beyond its nut can be an issue,…...

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Change(s) that REQUIRE a PHA revalidation AND RMP Update

There is some language in the EPA’s Risk Management Plan program requirements that tends to cause some confusion… The owner or operator of a stationary source shall revise and update the RMP submitted under §68.150 as follows: (5) Within six months of a change that requires a revised PHA or hazard review So when are we…...

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Interesting RMP Statistics – Where does your process rank?

NOTE: this data is a bit dated, but for those interested…An overview of some basic statistics derived from the RMP*Info database is informative and will help place more detailed assessments in context. As of this writing, the RMP*Info database contains information on a total of 14828 facilities containing 20210 chemical processes. Of these processes, 17529…...

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PSM Scenario Challenge – Response

Point -Counter Point PSM Discussion.  Below is my position and counter to “my opinion” is that of a friend who specializes in PSM for the refrigeration industry.  You can read his position at his website taocomplaince.com Scenario:  You have a freezer with racking. The racking inside this freezer needs to be replaced. You hire a…...

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Hotwork Safety

“Hot work” means work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operations.  Click “Read More” below to view and download the ppt…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Ammonia Gas Explosion

Explosion at Belle Vue: 2 injured between life and death Tuesday, September 27, 2011, 17:11 An explosion occurred this morning at the Belle-Vue brewery Leeuw-Saint-Pierre. Two people were seriously injured. Their prognosis is engaged. The leak was stopped. An ammonia leak occurred around 8:50 Tuesday when three workers from an outside firm conducted the dismantling of an old installation. ” The…...

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Use of High Visibility Vest in Safety Programs

Have you every walked up on a hotwork job and asked who is the fire watch, only to have five welders not even look up and point to each other? It happens, but there is a simple way to correct this behavioral problem – High Visibility Vests…. Membership Required You must be a member to...

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NFPA 30 offers some GREAT facility siting for NEW process vessels

Anyone involved with PSM/RMP knows about “facility siting” and all the attention it has gotten since the Texas City, TX incident in 2005.  Many companies struggle with this type of analysis, so I am passing along some great data that could be used during an expansion project at an existing facility or for a new…...

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