Most businesses have established their safe upper and lower limits for the most obvious process parameters such as pressures, temperatures, and levels; but in a flammable liquid process involving non-conductive flammable liquids establishing a safe upper and lower limit for flow is an ABSOLUTE MUST. There is not a Recognized and Generally Accepted Good Engineering…...
Establishing your safe upper and lower limits for FLOWS Read More »
This regulatory requirement is often mismanaged, which oftentimes results in many other related issues within a process safety management system. In this article, I will discuss a methodology a facility can apply in establishing its “safe upper and lower limits.” In this example, I will use process pressure, as it is the easiest to illustrate,…...
Establishing Safe Upper and Lower Limits Read More »
Key provisions of PSM OSHA’s preamble to the PSM Standard goes a long way to provide us insight as to why there are 14 elements to the standard and what each requirement in each element is intended to serve. The entire preamble is a very long read, but there are some key provisions in Section…...
Key provisions of the PSM Preamble Read More »
A requirement that many think is “common sense” and “simple” continues to appear on 3rd party audit reports and OSHA/EPA citations year after year. So why is something so “common” and “simple” so difficult to comply with? Often times we make something simple to difficult for our own good. In this article I want to…...
Tracking Corrective Actions to closure Read More »
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…....
Ammonia release via RV Read More »
As many of you know I have written extensively about flammable liquids safety, a true passion of mine within the safety field. But there is this SMALL detail that too many facilities are overlooking, but relying on in a very BIG way. Secondary Containment, or a “dike” as it is often called. Here are just…...
PSM, Flammable Liquids, & Secondary Containment Read More »
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…...
OSHA Launches their PSM Covered Chemical Facilities NEP Read More »
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…...
Flammable Liquids Tank Integrity Learnings Read More »
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,…...
Importance of MAINTANING your Explosion Proof Equipment (Video) Read More »
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…...
PHA and Loss of Power Read More »
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 Pressure Vessel “Cheat Sheet” Read More »
