Chemical Process Safety (PSM/RMP)

Some GREAT PHA Observations from one of the best in the business

Bryan, Here are some observations related to Bayer PHA effectiveness, as mentioned in the CSB report. The Chem Safety Board Incident Investigation Report for the Bayer incident was very critical regarding the quality / effectiveness of the PHA study. Please take a look over the attached extract from the report and keep these items in…...

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Some GREAT Process Safety Observations from one of the best in the business

You know, sometimes we need to have our efforts validated.  I put myself out there on a daily basis to try my best to educate those who are willing to listen to my ideas and rationale.  I take a lot of hits and it gets to me every once in a while.  But with over…...

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How do you define a PSM/RMP contractor and what does your evaluation process look like?

Although both EPA and OSHA use similar definitions to define who is an “incidental contractor” and those contractors who need to be evaluated to work in, on, or adjacent to a “covered process”, there is still much confusion on the intent of the “contractor element” and which type of contractors should be included and the…...

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Difference in Emergency SOPs and Emergency Response Plan

I have been asked to explain the difference between actions an operator may take during a process leak and the actions that the same operator may take as an “emergency responder” to the leak…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Unloading Hoses and PSM/RMP

Still today (2011) we come across facilities working so hard to be the best they can be in PSM/RMP and in 99% of their process they are exceeding expectations.  They are doing EVERYTHING WELL and running a VERY TIGHT ship…except for the loading and unloading of their Highly Hazardous Chemical (HHC). … Membership Required You must...

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IMPORTANT NOTICE regarding NH3 and LPG hoses

This notice is to inform you of an increase in the number of hazardous materials (HM) incidents involvingAnhydrous Ammonia (NH3) and Liquefied Petroleum Gas (LPG)… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Hot Work Requirements and Combustible Dusts

OSHA has clearly established that hotwork can not take place in the presence of combustible dusts. 1910.252(a)(2)(vi) Prohibited areas. Cutting or welding shall not be permitted in the following situations:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Hot Work Preparation and OSHA Requirements

We continue to see facility’s struggling with the basics of hot work safety. Most of these businesses are self insured and therefore do not have the extra set of eyes from their insurance carrier from time to time. But all do have catastrophic insurance and I am amazed that these carriers do not expect more…....

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Hot Work Safety and learning from others costly errors

Today I spent the day helping a company, insurance investigator and fire marshal investigate a Hot Work (HW) fire at a facility. The facility swore up and down that they follow their hotwork procedures to the letter and that there is no way that hotwork could cause the fire. When it came my time to…...

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Better be thinking MOC before you do RBI

That is PSM lingo for…when you are utilizing Risk Based Inspection (RBI) protocols and you wish to extend the inspection or PM frequencies on a piece of covered equipment, this is without a doubt a change that REQUIRES an MOC…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

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Mechanical integrity management of bulk storage tanks

Following the Buncefield incident the importance of preventing loss of containment from bulk storage tanks has come to the fore. A significant factor in ensuring contained fluids are not accidentally released is the continuing mechanical integrity of the tank structure. http://www.hse.gov.uk/research/rrhtm/rr760.htm… Membership Required You must be a member to access this content.View Membership LevelsAlready a...

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