We all are aware of… 68.25(h) Consideration of passive mitigation. Passive mitigation systems may be considered for the analysis of worst case provided that the mitigation system is capable of withstanding the release event triggering the scenario and would still function as intended. So I wish to challenge the claim that a WCS inside an…...
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Recently I was asked to help an organization with their Line Break/Process Opening Procedure and Permit. Anyone who has been through this process quickly realizes there is ZERO guidance from OSHA or any RAGAGEP as to what needs to be in the program and most notably the scope of the program. This organization has several…...
Just an FYI, as I know many of you are working on your 2014 5-year resubmittal, EPA issued an update to the RMP*eSUBMIT Users’ Manual in March 2014. No real changes in the manual other than some nice additions of “screen shots”. Here is a link to the new 2014 manual: http://www2.epa.gov/sites/production/files/2013-11/documents/rmpesubmit_users_manual.pdf … Membership Required You must...
We can get the 3rd degree when we start poking around a facility’s safety instrumented systems(s). It seems that there are those who believe they can build a SIS that no human can screw up and oh how wrong they are! Even OSHA was smart enough to require us to consider the consequences of the…...
I have received numerous e-mails and phone calls seeking help with using MARPLOT to obtain RMP OCA Populations so that this year RMP update will use 2010 Census Data. As I wrote last year, LANDVIEW is no longer a viable option and EPA has instructed us to use “other sources” specifically mentioning MARPLOT as an…...
Recent inspection programs for metallic pressure containment vessels and tanks have revealed cracking and damage in a considerable number of the vessels inspected. Safety and hazard evaluations of pressure vessels, as also presented in OSHA Instruction PUB 8-1.5, need to consider the consequences of a leakage or a rupture failure of a vessel. Two consequences…...
In the past 20 years or so we have seen Flame Resistant Clothing (FRC) come a long way in its design, ability, and costs that is VERY MUCH in favor of the end user and businesses. However, we still see the use of FRC as a much-overlooked layer of protection in many facilities and in…...
Seven hundred firefighters are struggling to extinguish a blaze at a food factory, hours after a chemical leak triggered a mass evacuation. One thousand eight hundred people were removed from the area. The incident happened in the small town of Bad Fallingbostel in the country’s north. Workers at the facility accidentally poured nitric acid into…...
Louisa Nara, Technical Director for the Center for Chemical Process Safety, sat down with Jordan Barab, Deputy Assistant Secretary of Labor for the Occupational Safety and Health Administration. Mr. Barab spoke at the 10th Annual GCPS in New Orleans giving an overview of Executive Order 13650, which aims to improve chemical facility and security…....
ASME Section IX focuses on the qualification of welders, as well as the procedures they use. The code’s Quality Assurance (QA) requirements are integrated into how an organization manages these documents to ensure compliance with the broader ASME piping code (B31 series). Under ASME IX, the manufacturer or contractor is responsible for the quality of…...
The purpose of this fact sheet is to compare some provisions of two key laws for preventing chemical process accidents in New Jersey. The facts presented are summaries of the laws. These laws are: The Occupational Safety and Health Act’s standard for Process Safety Management (PSM). This law is enforced by the U.S. Occupational Safety…...
