One of the more common omissions in SOPs is the inclusion of all the “safety systems and their functions” involved in the execution of the SOP. In this article, I will use the task of Truck/Railcar Unloading a Flammable Liquid to demonstrate the types of safety systems and their functions that may need to be…...
Yes, it is true… 1910.119(g)(2) states “Refresher training shall be provided at least every three years, and more often if necessary…” Please take note that the phrase “at least every” is used preceding the 3-year frequency, as well as OSHA explicitly states “more often if necessary”. In my 20+ years of developing, implementing and managing…...
This week the WV Attorney General Office (WVAGO) released their investigation report on the 2014 Elk River Chemical spill. This incident caused a mandatory Do-Not-Use (Water) order to be issued and more than 300,000 residents and countless businesses in a nine-county radius were without potable water for nine (9) days. This incident has now been…...
If I were to do 20 PSM/RMP audits per year with new clients, I estimate that I would have the following debate 15 times! In my Process Safety courses, I have a little fun with the phrase “Upwards and Unobstructed” as I make the class stand and repeat that phrase three times. But somehow/somewhere, this…...
PSM/RMP covered process(s) owner’s/operators have the option to manage the integrity of their plant and plan inspection from assessments of the risks of failure. They need to be able to demonstrate that the risk assessment and inspection planning processes are being implemented in an effective and appropriate manner. The aim of this report is to…...
With the recent fatal accident involving methyl mercaptan, I thought it would be a good time to remind us of another significant methyl mercaptan accident that claimed the lives of three workers. The recent accident claimed four workers via inhalation/asphyxiation and the one in 2001 involved ignition and the workers died as a result of…...
On December 11, 2014, the U.S. House of Representatives unanimously passed the Senate amendment to H.R. 4007, the Protecting and Securing Chemical Facilities from Terrorist Attacks Act – legislation to reinforce the protection and security of chemical facilities from terrorist attacks. Specifically, the House concurred in the Senate amendment to H.R. 4007 to extend the…...
In today’s business climate FREE info is hard to come by, especially from a recognized source. But in the past few years, The American Welding Society (AWS) has provided their staple Hotwork Safety standard Safety in Welding, Cutting, and Allied Processes available for FREE download. For the past several years I have been pushing this…...
Marsh’s 23rd edition of The 100 Largest Losses explores the largest property damage losses to impact the hydrocarbon extraction, transport, and processing industry, making it a valuable publication for risk professionals working across the energy sector. The information set out in this report is compiled from Marsh’s energy loss database, which holds almost 10,000 records…...
This is another lesson’s learned regarding piping and its mechanical integrity. On October 6, 2011, an explosion and subsequent fire occurred in the Middle Distillate Unifiner (MDU) area at a Canadian refinery and injured 52 workers. This third party analysis of the piping involved and its failure mode paint an ugly picture of how improper…...
Reading through the opening comments from OSHA and EPA at this weeks Senate Committee hearing discussing Executive Order 13650 – Improving Chemical Facility Safety and Security offered us some very interesting insights as to what OSHA and EPA are doing and planning in their efforts to improve process safety. Here are some of those that…...
My article earlier this year about line breaks on relief valve vent lines that are attached to a header/manifold got a lot of you to ask more questions about the practice of “line breaking” (or as some call it “process opening”). I have tried to answer each question but thought it may be helpful to…...
