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…...
How did EPA select the list of regulated substances? Read More »
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...
Another valve that needs to be Car-Sealed OPEN Read More »
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…...
Vulnerability of oil contaminated fire retardant coveralls Read More »
In the chemical industry, we had things a bit easier when it came to defining our process battery limits and this made it easy for us to define who was a PSM/RMP contractor. But things are not so easy in facilities where the PSM process is a small and not core to the business. We…...
Contractors and chemical process safety? Read More »
The following factors are critical to any SMS’s sucess. The SMS:• must be comprehensive and integrated with respect to the adopted control measures• must be implemented in practice and used as the primary means of ensuring safe operation• should be consistent with the understanding of risk gained from the Safety Assessment• should have sufficient focus…...
Features of successful Safety Management System (SMS) Read More »
My line of work brings me into contact with a lot of hazardous locations. Some weeks I feel I should just sleep in my FR coveralls! But each month we find errors in hazardous location classifications that could have disastrous results. This article is an attempt to bring to light some of the common errors…...
Electrical Classification for Hazardous Locations Read More »
A large metropolitan zoo maintenance employee may have disabled a warning light on a small train that derailed in 2009, sending 22 people to the hospital. The records are part of the evidence to be used in a February 2012 trial in which plaintiffs claim the zoo was negligent in its maintenance and operation of…...
How secure are your safety systems? Read More »
Just mention the letters “MOC” to an engineer or manager at a PSM/RMP facility and watch the eyes roll, the sighs let out, the clearing of throats, and so on. MOC is probably in the top three of the most despised elements of PSM/RMP; and yet, to no safety professionals surprise, failure of doing an…...
Management of Change (MOC) and Procedures Read More »
This week EPA announced a MAJOR RMP settlement agreement with one of the nation’s largest Ammonia distributors. This settlement agreement is HUGE in that it requires the company to install fixed Ammonia detectors at 14 different facilities in 12 states and over 2 EPA regions. These detectors are direct wired to the local FD, and…...
Is EPA setting a standard for PSM/RMP Staffing Levels? Read More »
At 7:17 a.m., on August 22, 2003, a cargo tank semitrailer arrived at a facility. The driver pulled the vehicle up to the fill location and helped an employee hook up to the fittings for a plant storage tank. According to the driver, about 7:40 a.m., the employee began transferring anhydrous ammonia, a poisonous and…...
Anhydrous Ammonia Stress Corrosion Cracking (SCC) Incident sends 5 to hospital Read More »
Learnings from this incident can be applied to any toxic/posiounous compressed gases. One fundamental rule…NEVER trap a liquid that has a high vapor pressure/low boiling point in a pipe or hose! To see the full size video, click on the “Read More” link below. … Membership Required You must be a member to access this...
Animation of January 23, 2010 Phosgene Accident Read More »
The CFATS Personnel Surety Program will provide high-risk chemical facilities with the mechanism to implement security measures to ensure that certain individuals are subject to screening for ties to terrorism. The program is necessary since conducting terrorist ties checks is an inherently governmental function because the federal governments Terrorist Screening Database (TSDB) is not publicly…...
CFATS Personnel Surety Privacy Impact Assessment is now available Read More »
