Chemical Process Safety (PSM/RMP)

Why would my NH3 ventilation discharge need to be a Hazardous Location?

I have received a lot of private comments on some of my recent posts regarding hazardous locations and ventilation.  As usual most are very positive and appreciative and a few were not so charming.  But one of my friends and clients has informed me that I should post my response to his questions as it worked…...

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Mechanical Ventilation – General Rules to live by

Many facilities will use mechanical ventilation to aid in reducing worker exposures, as well as controlling flammable atmospheres from becoming explosive.  There are some general rules of ventilation that should be applied in all cases and this article is an attempt to briefly mention the key points.  Mechanical ventilation systems are ONLY as good as…...

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The IMPORTANCE of Hydrostatic relief valves in Ammonia Systems

An accidental release of 12 tons of anhydrous ammonia at a storage/dispensing facility resulted in the hospitalization of five people and the evacuation of 550 residents. The unexpected release of anhydrous ammonia is believed to be due to a design error that may have caused a 3/4″ (1.91 cm) schedule 80 vent stack on the…...

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Difference between OSHA’s PSM and EPA’s RMP requirements

Ever heard anyone say, “PSM and RMP are identical except for the off-site consequence requirements”?  There are a lot of similarities between the two chemical safety regulations, but the two are very much different in more ways than just the “off-site consequence requirements.”  Most similarities are between RMP “Program 3 Prevention Program” and OSHA’s PSM…...

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Comparison of RMP and PSM Chemicals and Thresholds

Toxic Chemicals Regulated under RMP that are also Regulated under PSM [Alphabetical Order – 78 Substances] Chemical Name CAS No. RMP Threshold Quantity (lbs.) PSM Threshold Quantity (lbs.) Acrolein [2-Propenal] 107-02-8 5,000 150 Acrylonitrile [2-Propenenitrile] 107-13-1 20,000 Not Regulated Acrylyl chloride [2-Propenoyl chloride] 814-68-6 5,000 250 Allyl alcohol [2-Propen-1-ol] 107-18-6 15,000 Not Regulated Allylamine [2-Propen-1-amine]…...

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State of Massachusetts Hazardous Materials Processing regulation (527 CMR 33)

The Massachusetts Department of Fire Services (DFS) has enacted the Hazardous Materials Processing regulation (527 CMR 33).  The code was developed to help prevent the occurrence of incidents like the explosion in Leominster in 2005, the fire and explosion in Danvers in 2006 (see the CSB investigation), and the fire and explosion in Middleton in…...

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Challenging the NH3 Refrigeration & Electrical Classification (UPDATED 3/3/12)

Most ammonia refrigeration personnel know their refrigerant is flammable, but most would also tell us that they do not have any “Hazardous Locations” (e.g. Class 1, Div 1 or 2 locations) associated with their refrigeration process.  Most of these workers will explain their engine room/compressor room ventilation system is designed, installed, and maintained to ensure…...

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Is the act of loading/unloading a PSM/RMP chemical exempt from OSHA/EPA enforcement?

Is the act of loading/unloading a PSM/RMP chemical exempt from OSHA/EPA enforcement?  Absolutely not!  Somewhere this little fib began and it has spread like wildfire.  If you have a release of your HHC/EHS during unloading or loading, rest assured OSHA and/or EPA can investigate and inspection, and here’s why…… Membership Required You must be a...

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Can a PHA done for OSHA’s PSM be used for EPA’s RMP Compliance?

This is not meant to be a trick question, but many think it is.  A close examination of the specific wording in the PHA element of the RMP rule will quickly identify DIFFERENT wording than what is in OSHA’s PSM std (just another example of how these standards are NOT identical!)…. Membership Required You must...

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How many threads of a bolt must be showing outside a nut to meet RAGAGEP?

NOTE:  Members should also read Process Safety and our pipe flanges (type of bolts, threads showing, etc.) Some may claim this to be a trick question.  I assure you it is not meant to be, but as I will point out in this article, having too much bolt extending beyond its nut can be an issue,…...

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