Chemical Process Safety (PSM/RMP)

Can I use compressed air to blowdown/purge my Natural Gas piping?

I am always amazed at the number of facilities that do not understand their hazardous materials and the proper safety techniques in managing the hazards these HAZMATs present. Recently I came acorss a sitution where a contractor was left to “prepare piping for a line break”. The facility utilizes natural gas, as a fuel, within…...

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Anhydrous Ammonia is a FLAMMABLE GAS

For the doubting Thomas (no offense to actual people named Thomas), here is a bit of info to BELIEVE… I can not believe I have to say this in the Year 2026, but: Anhydrous Ammonia is a FLAMMABLE GAS Look it up on any reputable SDS. Yes, it is shipped as a non-flammable gas, but…...

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Chemical Security Program Statistics as of May 1, 2015

Improving the Nation’s Chemical Security Program Statistics as of May 1, 2015 More than 49,000 preliminary assessments were reviewed by DHS from facilities with chemicals of interest 3,348 facilities are currently covered by CFATS More than 3,000 facilities voluntarily removed, reduced, or modified their holdings of chemicals of interest 1,890 visits to assist facilities with…...

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Marking Hazardous (Classified) Locations

Marking Hazardous (Classified) Locations is a critical step in both compliance and personnel safety. While OSHA and the NEC (NFPA 70) mandate the classification of these areas, they are surprisingly quiet on exactly how to physically mark them. Because “invisible” hazards like flammable vapors or combustible dust can’t be seen, you should use a tiered…...

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OSHRC on PSM, Guarding, and HAZCOM from a Refinery NEP

This decision covers several interesting items and sets a HUGE precedent for RESPONSIBILITY of PHA and Audit items from the PREVIOUS owners PHAs and Audits.  The decision CONFIRMED that “utilities” within the process, in this case a “positive pressure unit” on a control room ventilation system, is a piece of COVERED EQUIPMENT.  It also establishes…...

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Explaining the difference in “stress relieved during fabrication”, Cold-Formed Heads, and Hot-formed Heads (CGA 2.1)

In the world of pressure vessels (like those governed by ASME Section VIII), the terms “stress relieved during fabrication”, Cold-Formed Heads, and Hot-formed Heads relate to heat, but they are very different techniques used in PV construction. PWHT is about treating the material after it’s been worked, while “hot formed heads” is about shaping the…...

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Excess Flow Valves… Installation, Testing and PM requirements

This is not the first time I have “beat up” on excess flow valves and the reliance on them as a “safeguard” in a PHA or process design.  Both EPA and OSHA are on record stating their displeasure of claiming these valves as a safeguard.  Now don’t get me wrong, these devices WORK and WORK…...

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DIR Releases Status Report on Process Safety Management Regulatory Oversight of California’s Petroleum Refineries

Christine Baker, Director of the Department of Industrial Relations (DIR), has submitted a legislatively-mandated status report on DIR and Cal/OSHA’s Process Safety Management (PSM) Regulatory Oversight. The report is required pursuant to the Budget Act of 2014 (Provisions 1 and 2 of item 7350-001-3121, Chapter 25, Statutes of 2014). A new assessment on the state’s…...

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EPA is getting in the game of issuing citations for NOT doing an MOC on “staffing changes”!

I am working on getting all of these RMP NOVs posted but found this one especially interesting… XXXXXXXXXX did not address the impact of the lock-out of the factory workers in August 2011 and hiring all new replacement workers.  Such extensive staffing changes could impact the safety and health of the XXXXX workers and should…...

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