This is an amazing summary from OSHA that shows us the number and severity of Hot Work Accidents involved with doing hot work on improperly prepared vessels. There are other hot work fatalities mixed in, but the vast majority of these incidents involved welding/cutting on vessels/containers that were NOT properly prepared. Check out 1910.252(a)(2)(vi)(C) and 1910.252(a)(3)(i) for […]
Over the last decade or so it has become popular to utilize a “relief header” in the ammonia refrigeration process. And in more recent years, the practice of installing an ammonia detector in this relief header has become very popular. Here are some random thoughts about these detectors that employers need to think through when
On 28th August 1992, in a food factory, a liquefied nitrogen storage tank catastrophically failed, causing the destruction of the upper half of the factory as well as damaging other factories and structures partially, including the outer walls, window glass, and shutters of 25 buildings, 39 parked vehicles consisting of busses, trucks and cars, and
UK’s HSE provides some EXCELLENT guidance on how ammonia refrigeration process safety can be managed. We have always taught our process safety courses with the underlying philosophy of process safety as PREVENT, PROTECT, MITIGATE, and in this HSE material they follow the same philosophy. This information is particularly helpful as they have matched up the
Today I learned of yet another SIGNIFICANT difference in complying with EPA’s RMP vs. OSHA’s PSM. Yes old dogs can learn new tricks and I am betting that I may not be the only old dog “out of compliance” with 68.200! We have been assisting a company with a US EPA RMP inspection and in
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
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
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
