The Hot Work Permit element of both OSHA’s PSM standard and EPA’s Risk Management Plan is one of the shortest elements’ of the 14 elements. Its presence is to require a written permit to be issued when performing Hot Work in/on/adjacent to a covered process. Some may not fully understand the need for this element,…...
Difference between the “Work Permit” content and “Training” content Read More »
On November 28, 1999, a blockage occurred in the South Teal Unit. The blockage or plug occurred somewhere in the recycle waste line on the second level of South Teal. This line brings crude Teal with excess aluminum to T-103, which feeds back to the reactors. During the night shift, they were able to blow…...
Line Break gone bad (Triethylaluminum) Read More »
A recent Coast Guard investigation involving a fire and subsequent loss of propulsion on board an inspected vessel serves as a reminder of safety issues caused by condensate forming in airlines. During the investigation, an underlying issue was discovered that caused condensate to form in airlines that supplied compressed air to the vessel’s air-operated engine…...
Dry Compressed Air is vital to safe equipment operation (USCG) Read More »
If you are a regular visitor to this site, you know I love to use the International Fire Code, which many states adopt in full or in some “revised” langauge as their “state fire/hazmat code”. One particular item that garners a lot of questions and comments is the IFC’s requirement that ALL hazardous materials (those…...
On May 11, 2023, @ 8:04 a.m., an employee working for an oil and gas support services company was found dead. On May 10th, the night before, the employee had instructed his coworkers from other contractors to go home, and he would finish the job. This was the last time anyone had spoken to the…...
Nitrogen (pneumatic) pressure testing fatality Read More »
This fatal incident displays the CRITICAL role of having procedures for responding to leaks, even “small releases.” 1910.119(n) Emergency planning and response The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan shall include procedures for…...
Employee Is Killed In Ammonia Overexposure Read More »
Having spent my entire career in Flame Retardant Clothing, I learned that improper laundering could render the PPE useless, maybe even hazardous to wear. In my time, we always had a contractor launder and maintain our FRC. It was not cheap, but it was necessary to ensure the PPE worked as intended when we needed…...
FRC program – Laundering Read More »
To simplify this, the Maximum Allowable Working Pressure (MAWP) is the maximum pressure at which the hose can operate routinely. Although, I strongly suggest the “operating ranges” be far less than the MAWP. However, achieving the MAWP does NOT mean the hose will necessarily fail. Where the hose will fail is called the “Burst Pressure.” …...
Difference between a hose’s MAWP and it’s “Burst Pressure” Read More »
The criteria for determining when to retire or repair FR clothing/garments/accessories MUST provide measurable or easily identifiable damage. The following are some means to DEFINE and QUANTIFY these deficiencies:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
When does FRC fail it’s user inspection? Read More »
In 2023, I began taking issue with the condition of Flame Retardant Clothing (FRC) being used in REQUIRED areas and tasks. We see garments that in no way would pass a “routine inspection” per NFPA limitations. My go to RAGAGEP for this is NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments…...
A Health and Safety Executive (HSE) investigation into a gasoline overfill of a carbon adsorption vapor recovery unit (VRU) revealed concerns with the design of the VRU. The overfill prevention system was NOT independent of the basic process control system (BPCS). When the BPCS failed the overfill prevention system also failed. This resulted in loss…...
OSHA’s PSM standard is over 30 years old, and EPA’s RMP standards/rule is approaching its 30th birthday fast. They are so 20th century (LOL)! This article is about how some of my clients are approaching their 3-year audits required by both standards. This approach embraces the “audit element” of the process safety management system as…...
PSM/RMP Auditing in the 21st Century Read More »
