Chemical Process Safety (PSM/RMP)

Management of Change (MOC) and Procedures

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…...

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Is EPA setting a standard for PSM/RMP Staffing Levels?

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…...

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Anhydrous Ammonia Stress Corrosion Cracking (SCC) Incident sends 5 to hospital

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…...

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Animation of January 23, 2010 Phosgene Accident

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...

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CFATS Personnel Surety Privacy Impact Assessment is now available

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…...

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Truck Drivers being your DOT HAZMAT Attendant and potential safety and health concerns

These days it is becoming common practice to utilize truck driver(s) of our hazardous material(s) deliveries to do more than just deliver the material.  The line of thought in doing this, is that the drivers must be “qualified” or they would not be allowed to transport the hazardous materials.  Well, they may be qualified to…...

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What does EPA’s RMP “General Duty Clause” actually require?

Almost weekly I see and hear the RMP “General Duty Clause” (GDC) being misquoted and improperly applied.  In this article I hope to clarify many of the myths and misconceptions of what EPA actually requires in the application of their GDC’s to RMP chemicals.  First and foremost, there is NO GET OUT OF JAIL FREE…...

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Buyer BEWARE regarding offsite Operator and Maintenance training courses

UPDATED 6/15/11 – A lot of claims are being made by many training organizations that they can solve ALL your PSM/RMP training needs.  Now let me set the record straight, I think a lot of these off-site training courses are a GREAT first pass for operators and maintenance to get the baseline understanding of the…...

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Process Safety and Security Guards

Many facilities have contract security at the access points into their facility.  But many facilities also expect their security guards to play a role in a facility emergency and in even rarer cases play a role in the facility’s safe work practices.  Last week I posted the 911 call involving the worker crushed by a…...

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HOTWORK Tank Explosion (Video)

This is video footage of the hotwork tank explosion next to the cruise ship incident that was in last nights incident alerts. An oil storage tank exploded in the port just metres from where a cruise ship was berthed – the explosion blew the lid off the tank and sent a fireball high into the…...

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PSM/RMP “co-location” or “proximity” when determing PSM/RMP Applicability

UPDATED on 5/31/11 to answer some specific questions I received over the holiday weekend…Scenario:  A process that is covered under PSM/RMP (a toxic liquefied gas under pressure) is in very close proximity to a propane system that is used solely as an on-site fuel. The propane system had always been exempted using the PSM exemption…...

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