Earlier this year, the US EPA cited a company for not having trained staff on-site at all times the Extremely Hazardous Substance (EHS) or Highly Hazardous Chemical (HHC) is on-site in quantities that exceed the Risk Management Plan threshold. The case (Click Here for my summary of the case) involved an ammonia distributor. The only…...
Process Safety, Staffing, and responding to alarms Read More »
ASME VIII, M-11 INSTALLATION OF SAFETY AND SAFETY RELIEF VALVES Spring loaded safety and safety relief valves normally should be installed in the upright position with the spindle vertical. Where space or piping configuration preclude such an installation, the valve may be installed in other than the vertical position provided that: (a) the valve design…...
Can a spring-loaded Pressure Safety Valve be installed horitionally? Read More »
Many THANKS to John Newquist, Assistant Regional Administrator at OSHA, Region V for sharing this data with us! In fiscal year 2012, Region V leads OSHA Regions in conducting Local Emphasis Program (LEP) involving PSM and ammonia seems to be a common theme with several anhydrous ammonia releases that have been investigated. I wanted to focus on…...
PSM Enforcement UPDATE from Region V Read More »
This is a PERFECT EXAMPLE of how a “non-covered” chemical within a PSM Covered Process can impact that PSM/RMP covered process. This can happen to any type of covered process; just not in a refinery! I have personally experienced a single acid line (not covered in the PSM program) leak over another pipe in a…...
A NON-PSM chemical impacting a PSM covered process Read More »
This DOSH Directive implements OSHA’s National Emphasis Program (NEP) for Chemical Facility Process Safety Management in the State of Washington. The purpose of the NEP is to reduce or eliminate workplace hazards associated with the catastrophic release of highly hazardous chemicals. Effective 5/2/2012. Statewide, a minimum of three inspections per year will be completed using…...
WA-OSHA latest State Plan to implement PSM CHEM NEP Read More »
Loss of Primary Containment (LOPC) is a term used to describe an event where a pipe or vessel leaks or fails, releasing its contents. No Process Hazards Analysis should be considered complete until each circuit of pipe/hose and vessel(s) has been reviewed for LOPC…. Membership Required You must be a member to access this content.View...
“LOPC” of an ammonia pipe in unoccupied refrigerated spaces Read More »
Town did not immediately notify the NRC as required following an incident when about 106 pounds of chlorine were released into the atmosphere. In addition, the town did not notify the state and did not provide the state or LEPC with written follow-up reports about the incident. EPA also identified other environmental violations during a…...
The OSHA offices in NY state have been very busy this year! This is about the fifth or sixth significant PSM case from that state in 2012. The others were Ammonia refrigeration; this one involved flammable liquids and gases. Items that OSHA took issue with include:… Membership Required You must be a member to access...
Flammable Liquid and Gas PSM Citations Read More »
The vessel you are viewing is part of a PSM Covered process. I have blacked out pipe and vessel labeling, as it does not matter what the HHC/EHS is or the type of process. Pay close attention to the sight glass column in the center of the picture. The process vessel shown has a safe…...
What ISA-84 can do for process safety Read More »
A Process Hazards Analysis (PHA) may very well be the best tool that has come along to the safety profession since the fire extinguisher! I am kidding of course, well sort of, as the PHA methodologies (and there are many) can be used in so many situations that it is used outside of PSM/RMP as…...
Considering failure of engineering controls in a PHA Read More »
Did you know that OSHA still does NOT require an actual Hotwork Permit, UNLESS you are doing the Hotwork in, on, or adjacent to a PSM covered process? It’s true, 1910.252(a)(2)(iv) uses the phrase “preferably in the form of a written permit“. It was not until OSHA put the Process Safety Management Standard (PSM) in place…...
Process Safety and Hotwork requirements Read More »
This overview outlines key elements of the ISA84 committee on process sector functional safety, including scope, purpose, history, and technical issues. It also provides a preview of the forthcoming 2nd edition of ANSI/ISA-84.00.01 (IEC 61511 Mod)…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Understanding ISA-84 Read More »
