In process safety circles, the word “remote” is found in several codes/standards. In OSHA’s Process Safety Management standard, we find it used in the Normally Unoccupied and Remote Facility (NURF) exemption (1910.119(a)(2)(iii). OSHA did us a favor by officially defining this phrase; however, they have never QUANTIFIED it. Normally unoccupied remote facility means a facility…...
Defining and Quantifying the term “Remote” Read More »
On May 23, 2023, @ 9:00 a.m. Employee #1 and Employee #2, both maintenance workers for a petroleum refinery, were troubleshooting an automated valve in the “Prime G Unit.” Flammable gasoline/hydrocarbons in the piping and flange portion of the automated valve were released, causing an explosion, and fire…. Membership Required You must be a member...
Line Break gone bad (Flammable gasoline/hydrocarbons) Read More »
The word “adjacent” may be small in terms of letters used to spell it, but it has an enormous impact on the world of process safety. Both OSHA’s Process Safety Standard (1910.119) and EPA’s Risk Management Plan (Part 68) use the word “adjacent.” Here is how Webster defines “adjacent” adjacent (adjective): not distant: nearby It…...
Defining and Quantify the terms “Adjacent and Near” Read More »
A great and reliable resource to help comply with… 1910.119(f)(1)(iii)(C) Control measures to be taken if physical contact or airborne exposure occurs; https://www.cdc.gov/chemicalemergencies/factsheets/ammonia.html … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Control measures to be taken if physical contact or airborne exposure occurs Read More »
This week, OSHA posted an LOI regarding terms used in the PSM Standard, and this LOI has generated some discussions amongst some SAFTENG members, most notably… How are we required to document our HAZLOCs? In OSHA’s LOI, it referenced 1910.307 Hazardous Locations standard which simply states: (emphasis by me) 1910.307(b) Documentation All areas designated as…...
Documenting a HAZLOC; Defining and Quantifying MATTERS! Read More »
On June 18, 2021, at 6:30 p.m. an employee was working for a firm that operated electric power generation facilities. He was working at a natural gas-fired power plant. He and a coworker were restoring a natural gas filter system at the power plant by aligning valves after a maintenance crew had replaced filter media…....
Torque MATTERS, FATAL failure of NG filter system at Power Plant Read More »
At 9:20 a.m. on July 12, 2023, an employee working as a supervisor was testing for leaks in a tank at a leak test station. Tanks are laid on their side for leak tests. The top of the tank faced the pressure test chamber, and the bottom faced the opposite direction. The employee began grinding…...
Pressure Testing GONE BAD (Vessel Failure) Read More »
Not only did OSHA update its Compliance Directive for Process Safety Management standard 1910.119, effective January 26, 2024, this week, they also posted a Letter of Interpretation (LOI) clarifying several key terms used in its PSM Standard. Terms defined include: Employer Employee Access, as used in the EP element Accessible, as used in the SOP…...
OSHA clarifies some PSM standard terms Read More »
As I continue my efforts to educate the safety profession in process safety and, more specifically, on the differences between welded pipe joints versus flanged pipe joints, this topic usually comes up. The big question that is the 800-pound gorilla in the room is… If both welded and flanged joints are allowed in our flammable…...
NFPA 497 Welded Joints vs. Flanged Joints and HAZLOCs Read More »
This week, I am doing my intermediate 3-day process safety training course for a new client whose process HHC/EHS is Liquefied Petroleum Gas (LPG); however, this process is VERY different than the other clients I have whose HHC/EHS is LPG. My clients are END-USERS of LPG; this facility is NOT the user of the LPG;…...
NFPA 58 vs. NFPA 59 for my process RAGAGEP Read More »
I am teaching my 3-Day Intermediate Process Safety course this week, and one of the popular exercises we do on Day 1 is the “Vehicle Safety Challenge.” It is designed to teach students to begin thinking about Layers of Protection within the PREVENT-PROTECT-MITIGATE model. Five students in four (4) groups have 15 minutes to… Membership Required...
Prevent – Protect -Mitigation Training Exercise Read More »
One of the top questions we get regarding contractor safety is, “Do I have to evaluate, orientate, and audit subcontractors working for a contractor we hired?”. OSHA’s latest revision of their PSM CPL answered this question. Is the host employer of a PSM-covered facility responsible for the safety of subcontractors?… Membership Required You must be...
OSHA clarifies that sub-contractors fall under 1910.119(h) Read More »
