Chemical Process Safety (PSM/RMP)

Over the past several years I have written many articles on the “safeguards” that get listed in Process Hazards Analysis.  In this article I want to focus our attention on the flaws that so many facilities are making in their PHAs.  Some facilities are really doing themselves an injustice by listing safeguards that have little…...

In many chemical processes around the world, operators are making their rounds checking on those items that have been deemed “critical to process safety”.  These rounds usually include checking pressure, temperature, tell-tale gauges, tank levels, heat tracing, taking samples, etc.  But in many instances involving these checklists, one item is painfully obvious after an incident–…...

Most businesses have established their safe upper and lower limits for the most obvious process parameters such as pressures, temperatures, and levels; but in a flammable liquid process involving non-conductive flammable liquids establishing a safe upper and lower limit for flow is an ABSOLUTE MUST.  There is not a Recognized and Generally Accepted Good Engineering…...

This regulatory requirement is often mismanaged, which oftentimes results in many other related issues within a process safety management system. In this article, I will discuss a methodology a facility can apply in establishing its “safe upper and lower limits.” In this example, I will use process pressure, as it is the easiest to illustrate,…...

Key provisions of PSM OSHA’s preamble to the PSM Standard goes a long way to provide us insight as to why there are 14 elements to the standard and what each requirement in each element is intended to serve.  The entire preamble is a very long read, but there are some key provisions in Section…...

A requirement that many think is “common sense” and “simple” continues to appear on 3rd party audit reports and OSHA/EPA citations year after year. So why is something so “common” and “simple” so difficult to comply with? Often times we make something simple to difficult for our own good. In this article I want to…...

Executive Summary: Minor non-permanent injuries (to two operators), and more severe injuries to a third employee resulted when ammonia refrigerant vapor was released from a safety valve on the outdoor refrigerant condenser. Equipment failure, ambient conditions, inadequate staff training contributed. A certificate of inspection was issued with follow-up. A complete plant survey was conducted and additional certificates of inspection issued…....

As you know, EPA regulates certain hazardous chemical facilities under 40 CFR Part 68 – known as the EPA Chemical Accident Prevention or Risk Management Plan (RMP) program.  EPA is aware that state and local communities are major stakeholders in the RMP program, and as such the Agency would like to alert you to a…...