Chemical Process Safety (PSM/RMP)

What is your EPA Risk Management Plan “Hazard Index”?

One of the methods EPA uses to determine RMP inspection priorities is based on their use of the Wharton School’s Hazard Index, which is defined as  “the sum over all chemicals of log2 (maximum quantity of inventory on-site/threshold), or, alternatively, as the number of chemicals times log2 of the geometric mean of the maximum-to-threshold quantity…...

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Yep, its JUST Anhydrous Ammonia “in Refrigeration” (Part II)

UPDATED with the actual working EXCEL Spreadsheet so that members can sort the data as needed;as well I updated the #’s related to refrigeration below.  I had messed up my first sort and was off by a couple.   This week I raised a red flag regarding ammonia accidents after the UNLOADING FATALITY at a…...

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Canada got it right with their Process Safety standard (CSA Z767:17)

Canada’s consensus standard for Process Safety Management far surpasses OSHA and EPA’s versions.  My favorite upgrade is how senior management has a few of its own sections in the standard.  For example: Leadership commitment at all levels of an organization is key to achieving excellence in PSM and establishing a process safety culture. Management must…...

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Excellent Advice from a Relief Valve Manufacturer regarding how to go about establishing Safe Upper Limits

I have written often about how we should establish safe upper and lower limits for our covered process(s). (SAFTENG members can read Establishing Safe Upper and Lower Limits)  One mistake we have discussed is related to safe upper pressures and its relationship to the MAWP of process vessels. We continue to see errors in such…...

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OSHA’s Request for Information (RFI) regarding their PSM Standard has CLOSED, but here are the comments

There are some really good comments and there are some very political comments, which should be expected in this type of transfer of information. I did notice that NOT ONE of the commenters answered the 85 questions OSHA requested they answer to support their comments/positions. Here is what the RFI stated: OSHA is providing the…...

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Plant oil filter failure on compressor causes ammonia leak

Purpose This Alert is issued to inform employers, self-employed persons, designers, manufacturers and suppliers of ammonia plant of a recent incident involving the failure of an oil filter. Background The failure of an oil filter on an ammonia compressor caused an ammonia leak and subsequent evacuation. One person was admitted to hospital but was released…...

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“Our Initial Start-Up Procedure(s) are the same as our Normal Start-up Procedures”… Guess again!

How many times have you heard, or maybe you were the one saying it, that “our initial start-up is the same as normal start-up and that is why we do not have initial start-up procedures”? If I had a $20 bill each time we heard this I would be retired!!!!  Recently I was talking process…...

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CFATs newest FAQ Questions (Ammonium Nitrate)

Question Under the Chemical Facility Anti-terrorism Standards (CFATS), should a regulated facility submit a revised Top-Screen if it changes either the type (i.e., bulk versus portable packages/containers) or the amount of Ammonium Nitrate (AN) that it possesses?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Conducting a Fire Risk Assessment

The first step to emergency preparedness is defining and analyzing hazards. Although all hazards should be addressed, resource limitations usually do not allow this to happen all at once. Risk assessments are used to establish priorities so that the most dangerous situations are addressed first and those least likely to occur and least likely to…...

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OSHA asking for permission to inspect PSM facilities with fewer than 10 employees

OSHA, combined with our State Plan partners, has approximately 2,200 inspectors responsible for the health and safety of 130 million workers, employed at 8 million worksites around the nation.  Although workplace conditions today are much safer than when OSHA was created, over 4,300 workers are still killed in the workplace each year and millions are…...

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Are my Railcars on site covered under RMP? (Sulphur Trioxide and Flammables/ $21,788 w/ $200,000 SEP)

This is a topic I have written about several times before and EPA has made their position fairly clear in their RMP Q&A’s.  SAFTENG members can CLICK HERE to read the summary of the EPA Q&A’s regarding railcars that are NOT attached to a mode of transport (i.e. locomotive).  These railcars that sit out on…...

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