Chemical Process Safety (PSM/RMP)

I recently came across a client who for whatever reasons had two (2) Risk Management Plans submitted for the same group of buildings, structures, equipment, installations and substance emitting stationary activities which belong to the same industrial group, which are located on one contiguous property, which are under the control of the same person (or […]

One of the more common errors we come across in RMPs is the listing of earthquakes, floods, tornadoes and hurricanes as “major hazards”.  I can say without hesitation that if your facility is in Omaha, NE that you should not be listing a “hurricane” as a “major hazard” associated with your process.  But you very

Each label is REQUIRED to include the following components: Abbreviation for ammonia system components The physical state – either liquid, vapor, or both The marker body containing the word “ammonia” The pressure level – high or low The flow direction   Many thanks to Steve Stephenson

OSHA’s PSM standard requires Operating Procedures to address “special or unique hazards” 1910.119(f)(1)(iii) Safety and health considerations:…1910.119(f)(1)(iii)(E) Any special or unique hazards. This item is often not necessary with many of the PSM standard’s Highly Hazardous Chemicals; however, HFO-1234yf has a unique property that falls into this requirement.  HFO-1234yf is…

Cases of Stress Corrosion Cracking (SCC) in steel vessels using NH3 have been reported by members of the ammonia refrigeration industry. When NH3 is used as a refrigerant, it is kept at -33° C (-28° F). While it was once believed that NH3 SCC)could not occur at such low temperatures, both practical experience and experimental studies have shown

As I have written earlier, the new refrigerant HFO-1234yf is a Category 1 Flammable Gas.  This flammable gas is stored under pressure as a liquid, which by definition makes this material a candidate for a BLEVE risk assessment.  For those that are not familiar with the acronym BLEVE, it stands for Boiling Liquid Expanding Vapor

HFO-1234yf is a Category 1 Flammable Gas.  The manufacturers SDS(s) all say it, as well as 1910.1200 Appendix B. PLEASE see my article Refrigerant HFO-1234yf is a Flammable “4” in the NFPA 704 Diamond (Part 2) for the breakdown of these facts.  With this Cat 1 Flammable Gas comes the hazard of flash fire(s)/explosions.  Now

Cal/OSHA today issued 19 citations to a refinery for workplace safety and health violations following an investigation into the February explosion at the company’s Torrance refinery that injured four workers. The proposed penalties total $566,600.  Eighteen of the citations were classified as serious due to a realistic possibility of worker death or serious injury. Six

I have been seeing a lot of RMP citations for failure to UPDATE the facility’s RMP every five (5) years.  By far the number one issue this year based on the ESAs I have been trending.  But one question comes to mind… RMP differs in PSM in a couple of ways, one way being that

In the past couple of months OSHA has been rescinding LOIs and issuing new LOIs on PSM Retail Exemption and the 1% rule and at the top of these LOIs (posted online) is a “blanket statement” from OSHA that I find sort of humorous and sad at the same time… “OSHA requirements are set by