Chemical Process Safety (PSM/RMP)

On June 18, 2021, at 6:30 p.m. an employee was working for a firm that operated electric power generation facilities. He was working at a natural gas-fired power plant. He and a coworker were restoring a natural gas filter system at the power plant by aligning valves after a maintenance crew had replaced filter media…....

At 9:20 a.m. on July 12, 2023, an employee working as a supervisor was testing for leaks in a tank at a leak test station. Tanks are laid on their side for leak tests. The top of the tank faced the pressure test chamber, and the bottom faced the opposite direction. The employee began grinding…...

Not only did OSHA update its Compliance Directive for Process Safety Management standard 1910.119, effective January 26, 2024, this week, they also posted a Letter of Interpretation (LOI) clarifying several key terms used in its PSM Standard.  Terms defined include: Employer Employee Access, as used in the EP element Accessible, as used in the SOP…...

As I continue my efforts to educate the safety profession in process safety and, more specifically, on the differences between welded pipe joints versus flanged pipe joints, this topic usually comes up.  The big question that is the 800-pound gorilla in the room is… If both welded and flanged joints are allowed in our flammable…...

This week, I am doing my intermediate 3-day process safety training course for a new client whose process HHC/EHS is Liquefied Petroleum Gas (LPG); however, this process is VERY different than the other clients I have whose HHC/EHS is LPG.  My clients are END-USERS of LPG; this facility is NOT the user of the LPG;…...

I am teaching my 3-Day Intermediate Process Safety course this week, and one of the popular exercises we do on Day 1 is the “Vehicle Safety Challenge.”  It is designed to teach students to begin thinking about Layers of Protection within the PREVENT-PROTECT-MITIGATE model.  Five students in four (4) groups have 15 minutes to… Membership Required...

One of the top questions we get regarding contractor safety is, “Do I have to evaluate, orientate, and audit subcontractors working for a contractor we hired?”.  OSHA’s latest revision of their PSM CPL answered this question. Is the host employer of a PSM-covered facility responsible for the safety of subcontractors?… Membership Required You must be...

On December 14, 2023, OSHA published its revised Compliance Directive for Process Safety Management standard 1910.119, effective January 26, 2024. This new version is in Q7A format and was done nicely, although there are a number of things in the answers that I am sure will be challenged.  I have highlighted some of the interesting…...

Sweating the “small stuff” matters in process safety management.  Meeting the details of our chosen RAGAGEPs matters!  Although I am often told, “That is a picky audit finding,” it is what it is.  Far too many facilities believe that designing their process piping to be bolted flange assembly vs. welded joints is somehow easier; in…...

We have discussed the critical role of “torque” in constructing our chemical processes.  I catch a lot of flack for my insistence on this critical function, for which I am genuinely surprised.  But our piping design and construction RAGAGEP (ASME B31.3) is pretty clear on the matter, and now OSHA and EPA have “caught on”…...

Another pressuring test “gone bad”.  I want to remind anyone who wonders how to DEFINE and QUANTIFY a “safe distance” when piping is being pressure tested, especially when that test is a “pneumatic” test.  ASME PCC-2–2022, Repair of Pressure Equipment and Piping, Mandatory Appendix, 501-III, Safe Distance Calculations for Pneumatic Pressure Test is an EXCELLENT resource to…...