The following are all the “exemptions” permitted in EPA’s Risk Management Plan rule (40 CFR PART 68—Chemical Accident Prevention Provisions)… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Summary of the RMP Chemical Exemptions Read More »
Below is OSHA’s official position on the need for hydrostatic relief valves in an Ammonia Refrigeration process. This is a bold move on OSHA’s part as the Ammonia Refrigeration industry and their trade groups have consistently stated that a “trained operator” is better than a hydrostatic RV. (emphasis added by me)… Membership Required You must...
OSHA’s position on Hydrostatic Relief Valves and Ammonia Refrigeration Processes Read More »
Retail facilities are exempted from PSM requirements. At first glance, it appears this is a pretty broad exemption, as the standard just states. This section does not apply to:1910.119(a)(2)(i) Retail facilities; But as I wrote about last month, not all retail facilities selling a PSM Highly Hazardous Chemical (HHC) in the USA are exempt. In…...
As we have discussed before, the EPA broke down its RMP rule into three (3) programs, and each program has criteria that will place the process in one of the three. However, the one criterion that confuses some businesses is how EPA used the North American Industry Classification System (NAICS) to qualify a process for…...
EPA’s RMP and Program 3 NAICS #’s Read More »
Jan 26, 2006 – An accident occurred in a factory in Brazil during pneumatic pressure testing with air from pipework around a tank. There were no blind flanges placed to isolate the pipework to the tank; only the valves were closed. Probably one or more valves failed or were not closed as the tank underwent…...
Catastrophic Failure during pneumatic pressure test Read More »
What happens when you try to pull water out of a tank using a 3HP pump and leave the vent closed… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
The power of a vacuum (photo) Read More »
I have posted numerous fatal accidents that occurred during the pressure testing of piping and pressure vessels. Although hydrostatic testing involves less energy release should something fail vs. using pneumatic pressure, the hazard(s) are still HUGE and must be respected. This incident involved a propane bullet built in 1994 and placed into service in 1996,…...
Brittle Fracture (Catastrophic) Failure during HYDROTEST of Propane Bullet Read More »
A 43-year-old assemblyman died on May 26, 1999, from chest injuries he received earlier that day when struck by a high-pressure water jet emitted after the failure of a gasket during a hydrostatic test of a cooling coil for an air-cooled heat exchanger. At the time of the incident, the victim was part of a…...
Hydrostatic test of a cooling coil for an air-cooled heat exchanger fatality (OK-FACE) Read More »
A process, in terms of Process Safety Management, is defined as: “Any activity involving a regulated substance including any use, storage, manufacturing, handling or on-site movement of such substances, or any combination of these activities. For the purposes of this definition, any group of vessels that are interconnected, or separate vessels that are located such that a regulated substance could…...
What is a process? Read More »
One of the debates we routinely have with fellow process safety professionals is the adoption of NFPA 51B vs. meeting 1910.252(a) requirements for their Hot Work safe work practice. I am a huge fan of NFPA 51B, as it is much more up-to-date than OSHA’s 1910.252, which, by the way, was based on the first…...
Fire Watch for your roofing contractor may have a 2-hr requirement Read More »
A massive leak of liquefied chlorine gas created a dangerous cloud of poison gas over the city of Henderson, Nevada, in the early morning hours of May 6, 1991. Over 200 persons were examined at a local hospital for respiratory distress caused by inhalation of the chlorine, and approximately 30 were admitted for treatment. Some…...
Massive Leak of Liquefied Chlorine Gas (Henderson, NV 1991) Read More »
Those of us living within the realm of Process Safety Management know all too well the difficulty of controlling contractor work activities to a level that we are confident they are not increasing our process risks beyond our acceptable levels. Many contractors are offended by the fact that many PSM programs have multiple layers of…...
The advantage of utilizing a Contractor Work Permit Read More »
