Chemical Process Safety (PSM/RMP)

Flammable Liquids Tank Integrity Learnings

This is an Investigation Report that EVERY PSM/RMP risk manager who has FLAMMABLE LIQUIDS in their process MUST READ!  I would add that EVERYONE who has flammable liquid tanks on their site should read this report.  The report could be used as an example of: 1) the “Accident Domino Theory”, 2)  a TRACKING SYSTEM for…...

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Importance of MAINTANING your Explosion Proof Equipment (Video)

EXCELLENT video for those of us that have Hazardous Locations and utilize “explosion proof” equipment.  This is the type of equipment that contains an explosion within the device and does NOT allow the flammable atmosphere outside the device to be ignited.  This video CLEARLY shows how easy it is to DEFEAT this safety critical feature,…...

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PHA and Loss of Power

In some recent PHA’s for a client I have seen a pattern in some general assumptions that PHA teams should not be making, but often do.  It involves the “consequences” for scenarios such as “LOSS of ELECTRICTY”.  The catch is that there is a general assumption that with a “LOSS of ELECTRICTY” that everything shuts…...

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OSHA’s Pressure Vessel “Cheat Sheet”

Not many OSHA CHSO’s are knowledgeable on Pressure Vessel Safety and with CSHO’s having to be expert in ALL the OSHA regs, the leadership thought it would be nice if the field CSHO’s had some guidance and reference document they could use.  This document was actually published in the 1980’s, long before PSM came about. …...

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The Jack Rabbit Test Program Trial Summary – NH3 and CL2 Release Studies

Donald P. Storwold Jr., U.S. Army, Dugway Proving Ground, UT; and E. P. Argenta Jr., J. M. White, J. C. Pace, and S. B. Fox present the results of their DHS release study.  The presentation (w/ voice over and video) is OUTSTANDING!  Every user of Anhydrous Ammonia and Chlorine should be required to view this…...

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PSM Battery Limits – it may not be as simple as “Interconnected”

OSHA’s most recent PSM Letter of Interpretation (LOI) confirms their position on covered process battery limits. I struggle with this, as their position states, and I quote, “Neither the application paragraph nor the definition of “process,” states or implies that controls can limit the extent or boundaries of a PSM-covered process.” With this position, OSHA…...

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More OSHA PSM Citations on a NH3 Refrigeration Process (includes NO MOC on personnel changes!)

No mention if this inspection was an NEP, scheduled, or complaint; but 9 of 12 citations were PSM.  They include: 1) The employer did not develop P&IDs which accurately represent current equipment for the ammonia refrigerationsystem. 2) No periodic inspections of the energy control procedures at least annually. 3) The employer did not train affected…...

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Explosion of MDEA Storage Tank

In August 1999, an explosion in an MDEA storage tank at a Nitrogen Products plant in Alaska propelled the tank off its base and into the air.  The tank landed on an adjacent air-cooled heat exchanger filled with synthesis gas.  The impact of the tank on air-cooled heat exchangers initiated a second explosion and fire…....

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How did EPA select the list of regulated substances?

How did EPA select the substances to be included in their RMP rule? The chemical accident prevention provisions promulgated pursuant to Section 112(r) of the Clean Air Act (CAA) are designed to focus on chemicals that pose a significant hazard to the community in the event of an accidental release and to prevent and minimize…...

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Another valve that needs to be Car-Sealed OPEN

There is a “personnel safety” practice that is very common in the design of process plants, but it is not the best design for “process safety,” and I forgot to mention this in my earlier Car-Seal article. Here is the setup. Do you see anything wrong with the pressure gauge arrangement?… Membership Required You must...

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Vulnerability of oil contaminated fire retardant coveralls

Coveralls become oil-contaminated very rapidly in many work situations, particularly offshore, in some cases within one day. From time to time, there are significant hydrocarbon fires offshore (eg on the Rough Platform). There is evidence that frequent washing reduces the fire retardant properties of some materials, thereby increasing personal risk to persons and compromising their…...

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