Chemical Process Safety (PSM/RMP)

IL Pressure Vessel Inspection Frequency (DRAFT FM Procedure)

A Pressure Vessel subject to Internal Corrosion shall be defined as any metal Pressure Vessel using a processed product that can cause Corrosion, Erosion, Pitting, Cracking, or Deterioration, as defined in Part 2, 3.3 of the National Board Inspection Code. The intent is to verify the vessel is safe to operate.  Pressure Vessels subject to…...

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Chemical Security Program Statistics as of March 2, 2015

The Department of Homeland Security (DHS) continues to strengthen security at the Nation’s high-risk chemical facilities through the Chemical Facility Anti-Terrorism Standards (CFATS) program.  Chemical Security Program Statistics as of March 2, 2015: More than 48,000 preliminary assessments were reviewed by DHS from facilities with chemicals of interest 3,471 facilities are currently covered by CFATS…...

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Cal ARP Regulation Amendments 2015

As I posted back in August 2014, CAL EPA was looking to make changes to the CALARP rule.  The proposed petition process was rejected but the rest of the package was accepted and were approved by the Office of Administrative Law and took effect on January 1, 2015. The Governor’s Interagency Task Force on Refineries has suggested additional amendments…...

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Line Break Gone BAD due to IMPROPER LOTO and OSHRC vacates all OSHA citations (not a type-o!)

This is an interesting turn of events!  The ALJ upholds most of the citations and then OSHRC vacates them all. This after a 750-pound release of butylene oxide that occurred during a line break activity and was caused by an IMPROPER energy control plan.  One worker was diagnosed with “chemical pneumonia” due to his exposure to the…...

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Changes in Regulation of Agricultural Anhydrous Ammonia

The purpose of this letter is to make Agricultural Anhydrous Ammonia handlers in Iowa aware of new Anhydrous Ammonia Standards and changes the adaptation of the new standards and exceptions may bring. On December 15, 2014, CGA (Compressed Gas Association) received a Notification of Final Action on ANSI/CGA G-2.1, 2014, Safety Requirements for the Storage…...

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Do you “certify” your 3-year PSM/RMP compliance audits?

Not a trick question but boy do we get “the look” when we ask the question just as it is written in 68.79 and .119(o).  What do OSHA and EPA mean by certifying an audit?  Who does this certification? Is this a formal exercise of certifying?  Why did OSHA/EPA use this term in the standard? …...

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Consider the assumptions made during a PHA Facility Siting Assessment (Pipe Bridges)

I recently participated in a PHA for a large flammable liquids process and during the “facility siting” portion of the PHA we took a detailed tour of the process. During which, several significant “impact” hazards were identified. Of course, the long-time engineering manager (40 plus years of fine service at the facility) quickly went to the…...

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Anhydrous Ammonia at Refrigeration Facilities Under Scrutiny by U.S. EPA

This Alert is intended to inform the industry that companies must take responsibility to prevent accidental releases of dangerous chemicals like anhydrous ammonia through compliance with CAA’s Chemical Accident Prevention Program.   Evidence gathered by the U.S. Environmental Protection Agency (EPA) indicates that some refrigeration facilities may be failing to properly manage hazardous chemicals, including…...

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