Chemical Process Safety (PSM/RMP)

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…...

It’s here!!!!!!  OSHA announced today they are officially EXPANDING the PSM Covered Chemical Facilities National Emphasis Program (NEP) to cover the ENTIRE NATION and State Plans.  This Instruction applies OSHA-wide. Both programmed and unprogrammed inspections will take place in all OSHA Regions and will begin immediately in all Regions.  Some Key Points to share with…...

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,…...

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…...

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. …...

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…...

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…...