I want to encourage you to ask around and maybe even go as far as auditing around this learning opportunity to assess if this is going on at your facility. If your process involves doing preventive maintenance on flame arrestors and/or conservation vents, what controls are in place for this “routine work”? What kind of…...
Back in September 2013 (Members CLICK HERE) I updated you on the fact that LANDVIEW was going away and how this would impact us this year when it comes time to make our 5-year update. Now for those of you who are using ALOHA/MARPLOT to plot your Off-Site Consequence Analysis you can get your 2010 census…...
Although this “guidance” is provided by Ohio EPA and is meant for ONLY facilities located in the state of Ohio, this guidance is an EXCELLENT breakdown of how a facility should view “co-located” containers of their Extremely Hazardous Substances to determine if their “co-located containers/vessels” are actually a “process” that would fall under the CAA’s…...
EPA announced that a food processing facility has agreed to pay a $19,049 penalty for failing to properly report an ammonia release at its facility. According to EPA, the facility released at least 450 pounds of anhydrous ammonia to the air on September 12, 2012. Employees were evacuated and the local Fire Department responded to a 911…...
This week, OSHA once again showed their intent to issue PPE citations during PSM NEP audits. They are very content to issue a citation against 1910.132(a) or (d) when the process contains a flammable liquid and somehow the employer’s PPE Hazard Assessment determined that Flame Retardant Clothing (FRC) is not necessary. But there is another…...
Over the past several months we have been working with a confidential client who has afforded me with permission to post this “learning opportunity” for others. This incident, although minor this time, was recognized as having the potential to end the business so this organization is pulling out all the stops to identify failures. Once…...
What happened? During a recent inspection at a facility, an NOPSEMA inspector observed vibration-induced fatigue cracking and evidence of rectification work carried out on several small-bore connections on seawater cooling pipes. On further investigation, it was discovered that there had also been a recent fatigue failure on the hydrocarbon test separator header. Fortunately, the operator…...
Early last year I wrote about some trade organizations that were “revising” their codes/practices, which in turn were making them “more flexible”. I stated it then and I will state it again, this time along with the US Chemical Safety Board… this is a REALLY BAD idea. Both OSHA and EPA wrote “performance oriented” standards…...
Ever wanted to know what an American Petroleum Institute (API) code or practice said? Well now you may be in luck; as API is providing online public access to many of their key industry standards, including a broad range of safety standards, most of which were previously only available by purchase. These standards will be…...
Recently the SAFTENG team was hired to provide some safety services during a turn-around/shutdown at a PSM/RMP facility . While out and about we came across a very interesting find… a speciality contractor with facial hair. Now this was not just any speciality contractor and the reason we were so surprised was the facility had,…...
PLEASE NOTE: this posting is about pressure vessel RVs discharing back into the process and not Hydrostatic RVs or pump RVs. Scenario: Process is shutdown using the emergency stop (e-stop) systems because the building is on fire. On the roof of the building/plant sit a number of vessels that have a “flooded system” which contains…...
US EPA is concerned that some natural gas processing plants that store and process liquefied petroleum gas (LPG) may not be designed in accordance with applicable industry standards and codes. When undertaking compliance monitoring activities at such natural gas processing plants, EPA considers whether facilities are designed in accordance with recognized and generally accepted good…...
